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Brexit: Hard Landing/Soft Landing or Down the Rabbit Hole: What’s Ahead?

This is the third in an ongoing series of blog posts by Foley & Lardner LLP on the implications of the June 23, 2016 referendum decision in the United Kingdom (“UK”) to exit the European Union (“EU”)...more

Non-Dom Reforms Update – United Kingdom

Summary - Following the United Kingdom’s vote to leave the European Union on 23 June, and the change of Prime Minister and to the UK Government, there was significant uncertainty regarding what would happen to the...more

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

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

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

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

The Hidden Cost Of “Going Home” — the Expatriation Tax for Long-Term Permanent Residents Who Return to Their Home Countries

People immigrate to the United States for many different reasons. Many come here for work reasons and, somewhere along the way, obtain permanent resident status, otherwise known as holding a “green card.” They may work in the...more

Will Travel Insurance Cover This? Your Passport Can Be Denied or Revoked for Seriously Delinquent Taxes

If you wrote “travel more” on your 2016 New Year’s resolutions list, you may want to make sure you’re in good standing with the IRS before you make plans to wander too far from home. In early December 2015, legislation was...more

U.S. Pre-Immigration Tax Planning

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

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

New Law Will Revoke Passports for Certain U.S. Citizens with Tax Debts

Legislation passed by the U.S. Congress December 3 and signed by President Obama on December 4 would allow the IRS to work with the State Department to revoke or deny the passport of a U.S. citizen with “seriously delinquent...more

Find Out What Is Hidden Within The New FAST Act

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

Delinquent Taxes May Mean No Passport

Individuals who are “seriously delinquent” on their taxes may not be able to obtain or renew a passport under a new law signed December 4, 2015. The provision is part of the Fixing America’s Surface Transportation Act, aimed...more

Chancellor Scraps Permanent Non-Dom Status!

Until now, the UK has been one of the most welcoming jurisdictions in Europe where non-UK-domiciled individuals could live. Today, Chancellor George Osborne announced in his Summer Budget that from April 2017 the rules...more

Estate Planning for Non-U.S. Citizens

In This Presentation: - Basic Rules - Determination of Residency for Estate Tax purposes - Tax Rules - Estate and Gift Tax Treaties - Asset Situs Rules - Taxation of Life Insurance...more

Coming to America Part II: Legal & Cultural Challenges for Emerging Companies

In our last post “Coming to America Part I,” we discussed why emerging companies would choose enter the US market to do business. In this post, we will discuss the many interrelated legal and cultural factors non-US companies...more

As Expatriations Increase, Potential Relief for “Accidental” U.S. Citizens

According to Treasury reports, 3,417 U.S. citizens relinquished their U.S. citizenship in 2014, which is more than the number of expatriations reported in prior years. As required by law, the Treasury publishes a quarterly...more

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

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

National Security: Removing Barriers to Intra-Governmental Sharing of Information

The House of Commons in Canada is back in session. The federal Conservative Government wasted no time in introducing sweeping anti-terrorism bill (Bill C-51, the Anti-terrorism Act, 2015). I canvassed the legislative and...more

CBP Designates Preferred Ports of Entry for First-Time Canadian TN and L-1 Applicants

U.S. Customs and Border Protection (CBP) is the agency charged with overseeing and facilitating international travel and trade across the borders of the United States. The CBP’s mandate includes responsibility over...more

2015 Regulatory Challenges Burdening Manufacturers

As we roll into the new year, this edition of the Manufacturing Industry Advisor takes a look at some of the key regulatory issues that manufacturers will be facing in 2015. Based on recent discussions with key legislative...more

Informal Surrender Of Green Card Doesn’t Work

The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes....more

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

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...

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

Scholarships, Grants, And Foreign Students— Tax Compliance Tips For U.S. Institutions

In recent years, record numbers of foreign students have enrolled in graduate and under- graduate programs at U.S. colleges and universities. During the 2012-2013 academic year, their numbers topped 800,000—the seventh...more

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

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