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Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

7/7/2014 - Check the Box Rules Cross-Border Foreign Entities IRS Tax Planning

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

6/13/2014 - Controlled Foreign Corporations Corporate Conversions Dividends Foreign Corporations Foreign Investment Jurisdiction Repatriation Shareholders Subpart F Tax Planning Tax Treaty

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more

5/29/2014 - Aerospace Blue Origin CFC Foreign Tax Income Taxes NASA Passive Activity Privatization SpaceX Tax Credits Tax Planning Tax Rates Virgin Galactic

IRS Recognizes Same Sex Marriages, Even If States Do Not

The Internal Revenue Service has announced that same sex couples legally married in a state whose laws authorize such a marriage will be deemed to be married for Federal tax purposes, even if they live in a state (such as...more

9/2/2013 - Federal Taxes Income Taxes IRS Same-Sex Marriage

Tax Planning Important For Foreign Purchasers Of U.S. Real Estate

It is no secret that the South Florida real estate market has been a buying opportunity for wealthy foreigners, in light of the decline in U.S. home prices and the lower value of the U.S. dollar against some foreign...more

8/21/2013 - FIRPTA Foreign Investment Income Taxes

Spike In Real Estate Creates Tax Planning Opportunities For South Florida Property Owners

Although it may come as a surprise to many, it is no secret that South Florida property values are on the rise. ...more

6/14/2013 - Capital Gains Housing Market Income Taxes Land Developers Real Estate Market Tax Planning

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

4/16/2013 - Capital Gains Dividends Expatriates Foreign Earned Income Income Taxes Residency Status Tax Exemptions

Real Estate Professionals Navigating The New 3.8% Medicare Tax

With a new year comes a new beginning. While New Year’s Day is typically viewed as a chance to start fresh and make changes in our personal lives, for many people New Year’s Day in 2013 took a different tone. Instead of...more

2/1/2013 - 3.8% Medicare Tax Net Investment Income Real Estate Professionals Rental Income

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