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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Banking & Financial Services E-Note - December 2016

by Burr & Forman on

Last month, the IRS issued final regulations repealing its rule requiring that a Form 1099-C be filed whenever a financial institution (or certain other limited taxpayers) fails to receive payment on a debt for 36 consecutive...more

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

by Gerald Nowotny on

Panorama - A Parte I desta série teve enfoque no pesadelo e problema imprevisto de declarações de impostos não apresentadas para imigrantes não registrados. As consequências de "empurrar o problema com a barriga"...more

Broken Dreams - How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants - Part 2

by Gerald Nowotny on

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

The Brexit

by King & Spalding on

The result of yesterday's vote of the UK electorate is in favour of the UK leaving the European Union. This is merely the first step in a very long road (up to two years) which begins with the UK serving notice of its...more

U.S. Pre-Immigration Tax Planning

by Carlton Fields on

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Infrastructure, Energy and Land: Russia’s renewed focus on the development of the Russian Far East

by King & Spalding on

Over the past two years, Russia has expressed its intent to significantly increase investment opportunities in the Russian Far East including in the areas of infrastructure development, ship and oil rig building, trade,...more

Find Out What Is Hidden Within The New FAST Act

by Ervin Cohen & Jessup LLP on

On December 4, 2015, the President signed into law the Fixing America’s Surface Transportation Act, or FAST Act. There’s not much in there about taxes, but here are the plums hidden in the Act’s 1,300 page text...more

Be Careful for What You Wish For! - Reconsidering the Tax Traps of the EB-5 Visa

by Gerald Nowotny on

EB-5 Visas have been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. Nothing hard to understand about that. The combination of...more

Bye Bye Brazil – Considerações Tributárias no Planejamento de Investimento Brasileiro dentro dos Estados Unidos - Parte 1

by Gerald Nowotny on

Sou advogado tributário americano. Me formei na academia militar do exército americano em West Point, Nova Iorque. Me graduei em Espanhol e Português. Meus professores eram um tentente coronel do exercito brasileiro formado...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part 3 - Inbound Investment Real...

by Gerald Nowotny on

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part II – Additional Income Tax...

by Gerald Nowotny on

I have mentioned in prior articles my affiliation with the South Florida law firm Osborne and Osborne, PA in Boca Raton. Back to the beginning! Boca Raton is where I started right out of the Army in 1987. I moved to Miami for...more

Bye Bye Brazil!- Tax Planning Considerations for Brazilian Investment in the United States: Part I – Income Tax Considerations

by Gerald Nowotny on

Overview - I have mentioned in prior articles that I was a Spanish and Portuguese major as an undergraduate. During the time that I was attending law school at the University of Miami, the early 1990’s, the Brazilians...more

Getting a Green Card Subjects Noncitizens to U.S. Foreign Bank Account Reporting Requirements

A resident or citizen of a country other than the United States who obtains lawful permanent resident status in the United States, often referred to as a “green card,” becomes a resident of the United States for U.S. income...more

Leaving Mainland America Yet Remaining in the United States—Puerto Rican Residency as an Alternative To Expatriation

by Gerald Nowotny on

OVERVIEW - One of the news items that generates political fireworks each year is the number and names of famous Americans who renounce their U.S. citizenship. According to the Wall Street Journal, the United States is...more

Nonresident Alien Spouse Not Liable for Penalties

by Sanford Millar on

There are an unknown number of U.S. citizens married to nonresident aliens. Many of these taxpayers have filed joint income tax returns. Most are likely to have filed joint income tax returns (Form 1040) without having...more

Investing In Georgia: Economic Development Newsletter - June 2013

by King & Spalding on

Welcome to King & Spalding's economic development news bulletin, Investing in Georgia. In this edition, you will find: - An economic-impact study linking the use of tax-exempt municipal bonds to the development of our...more

I Want to "Leave" in America - Puerto Rican Residency as an Alternative to Expatriation

by Gerald Nowotny on

Overview - One of the things that generates political fireworks each year is the number and names of famous Americans renouncing their U.S. citizenship. The number is 2012 was about 1800. Regardless of whether you are...more

A Tax Opinion CAn Protect EB-5 VISA Status.

by Sanford Millar on

An EB-5 Visa is known as an "investor" visa. The following is an explanation of the EB-5 program...more

EB-5 Visas Applicant Need Tax Opinions

by Sanford Millar on

An EB-5 Visa is known as an “investor” visa. The following is an explanation of the EB-5 program...more

Soy Boricua - Rethinking Inbound Tax Planning for Wealthy Latin American Moving to the U.S.

by Gerald Nowotny on

Overview - In case you did not know, Miami is the capital of Latin American. It is the port of entry for Latin Americans from Central and South America. Historically, wealthy Mexicans have liked California and Texas...more

I Want to Live in America!- Part I Tax Planning Considerations for Foreign Scientists and Engineers

by Gerald Nowotny on

Overview - As discussions regarding immigration reform continue to unfold, one point that is not under discussion or subject to debate is the contribution of foreign scientists and engineers to the New Economy. The statistics...more

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

Congress Returns from Spring Recess

by Mintz Levin on

Congress returns to Washington today after a two-week district work period. As we enter the second quarter of the year, we are likely to see continued debate and some progress on: Budget & Appropriations; Presidential...more

Investing In Georgia: Economic Development Newsletter - February 2013

by King & Spalding on

In This Issue: Welcome to King & Spalding's economic development news bulletin,Investing in Georgia. In this edition, you will find: - An overview of the sequester, debt ceilings, continuing resolutions to fund...more

Tax Traps Accompany EB-5 Visas

by Sanford Millar on

EB-5 Visas are sought after investment based pathways to a Green card. An EB-5 Visa is described in Wikipedia as follows...more

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