Read Tax Law news, alerts, and legal commentary from leading lawyers and law firms:
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Micah Green on U.S. Fiscal Policy
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Polsinelli Shughart Election Analysis and Legal Insight
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Why choose Canada for a Cross-Border Income Trust (CBIT)?
What is a Canadian Cross-Border Income Trust (CBIT)?
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Should you Opt-Out of the Voluntary Disclosure Program?
Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers
Cost of Voluntry Asset Disclosure Program
The death or disability of a taxpayer who has failed to timely file a Report of Foreign Bank or Financial Account (FBAR) can present difficult problems for fiduciaries like trustees, estate executors and conservators. The...more
The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more
Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a...more
The curiously titled "Heroes Earnings Assistance and Relief Tax Act of 2008" became law 17 June 2008. This was the third major revision of expatriation rules in 12 years. While the Act provides laudable benefits to armed...more
International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with...more
The German Federal Tax Court clarified that distributions from foreign trusts to beneficiaries resident in Germany are subject to German gift taxation, but did not address the possible imposition of both gift and income tax...more
To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more
The March 21, 2013 Federal Budget changed the tax law applicable to the pipeline abandonment trust (Trust) structure that has been submitted to the National Energy Board (NEB) as the proposed mechanism for...more
Originally published in Private Client Multi-Jurisdictional Guide 2012/13.
In This Issue:
Taxation; Wills and Estate Administration; Succession Regimes; Intestacy; Trusts; Ownership and Familial Relationships;...more
Code §2501(a)(2) provides that, except as to certain expatriates, U.S. gift taxes do not apply to the transfer of intangible property by a nonresident not a citizen of the United States. This exemption is big enough to drive...more
In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more
In This Issue:
Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from...more
It has long been popular for high net-worth people who are not domiciled in the United Kingdom (“non-doms”) to form an offshore company, often in the British Virgin Islands (“BVI”), for the purposes of holding property in the...more
Code §2801 imposes U.S. transfer taxes on transfers by former U.S. persons who have expatriated if the transfer is to a U.S. person. This tax is imposed on the U.S. recipient. A recent article by Joseph Toce, Jr. and Joseph...more
Now that the election is over, we anticipate having some guidance soon with respect to the numerous tax and planning issues that have been mired in uncertainty for the past two years. Many tax benefits are scheduled to...more
A. Overview -
Part I of this series focused on the impact of impending tax increases following the Presidential Election for corporate executives and salaried professionals. Part II of the series will focus on...more
On Wednesday, October 24, 2012 the Canadian Federal Department of Finance tabled in the House of Commons a large detailed Notice of Ways and Means Motion (“NWMM”) to amend the Income Tax Act (Canada) and a variety of other...more
On October 24, 2012, the Federal Minister of Finance released a detailed Notice of Ways and Means Motion to implement outstanding technical tax amendments, including significant amendments to Canada’s income tax rules...more
When is it right to op-out of the voluntary disclosure program, knowing when to stay in and when to get out could be the difference of saving a massive amount of money and staying out of jail. Talk to a professional who can...more
Originally published in Insights Legal Affairs.
Do you own a vacation home in Mexico? Have a bank account in Hong Kong? Has your spouse retained Canadian citizenship? Are you a long-term U.S. resident who was born in the...more
Last year France passed legislation which is aimed at taxing assets held through trusts where there is a connection with France. Effective as of July 31, 2011, this legislation imposes tax reporting obligations on trustees...more
Dr. James formed an irrevocable trust in Nevis, West Indies for asset protection purposes. He properly reported the trust to the IRS on a Form 3520-A, but neglected to file a Form 3520. He is at risk for a penalty of the...more
Every time I’m presented with a contract, I’m quickly transported to a small room in which Willy Wonka, played by Gene Wilder, is vehemently scolding the good natured Charlie Bucket and the poor, protective Grandpa Joe:
Overview of Fideicomisos
If you own a home or a vacation home in Mexico, chances are that your property is held in a fideicomiso. A fideicomiso is a contractual arrangement that is arguably something in between a trust...more
When someone dies with foreign assets, the heirs need to know the law and what their options are to best preserve the bulk of the inheritance. It can be a complicated business sorting out foreign assets and well worth your...more
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