Charles (Chuck) Rubin – Gutter Chaves Josepher Rubin Forman Fleisher P.A.

2101 NW Corporate Blvd. Suite 107
Boca Raton, Florida 33431, United States

  • 561-998-7847

IRS Applies 20th Century Analysis To 21st Century Social Organization

Code §501(c)(7) provides an exemption from federal income tax for clubs organized substantially for pleasure, recreation, and other nonprofitable purposes if no part its net earnings inures to the benefit of a private…more
| Business Organizations, Education, Taxation, Nonprofit Law

Time Limitations On Receiving Late Proof Of Foreign Status For Portfolio Interest Exemption Payments

Code Section 871(h) provides non-U.S. persons with a valuable exemption from U.S. income taxes on interest paid on registered U.S. obligations, commonly referred to as the portfolio interest exemption. Before a payor is…more
| Civil Procedure, Finance & Banking, International Law & Trade, Taxation

Personal Goodwill Of Employee Reduces Estate Tax Value Of Corporate Stock

The question of “personal goodwill” often comes up in sales of corporate assets. When a business is sold, the shareholder will often seek to sell his or her “personal goodwill” in the business separately from the corporation’s…more
| Commercial Law & Contracts, Taxation, Wills, Trusts, & Estate Planning

‘F’ Reorganization Is Not An Inversion Transaction

The hot tax policy discussion these days is about corporate inversions. Rather than entice capital to stay in the U.S. with favorable tax rates (i.e., using the carrot), it is being proposed to enhance corporate inversion rules…more
| Commercial Law & Contracts, International Law & Trade, Taxation

Part VI – Willful Or Non-Willful Offshore Omissions & Conclusion

Below is Part 6 and the conclusion of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures…more
| Civil Procedure, Criminal Law, Finance & Banking, International Law & Trade, Taxation

No Disclaiming Federal Tax Liability

Chris owed money to the IRS, and had federal tax liens filed against him. He was also a 1/3 beneficiary of his mother’s estate. To avoid the IRS collecting against his share of the estate, Chris disclaimed his interest as…more
| Taxation, Wills, Trusts, & Estate Planning

Part V - Minimizing Risk Of Criminal Prosicution By Meeting Requirements For A Voluntary Discover In IRM 9.5.11.9

Below is Part 5 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures…more
| Criminal Law, Finance & Banking, International Law & Trade, Taxation

Northwestern University Football Players Are Not Employees

Recently, the National Labor Relations Board ruled that grant-in-aid scholarship football players at Northwestern University are “employees” under the National Labor Relations Act. This has raised the question whether such…more
| Art, Entertainment, & Sports Law, Education, Labor & Employment Law, Taxation

Part 4 - The Delinquent International Return Submission Procedured

Here is Part 4 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures…more
| Finance & Banking, International Law & Trade, Taxation

Applicable Federal Rates - August 2014

See Charts below for August 2014 Tax Rates…more
| Finance & Banking, Taxation

Part 3 – The Delinquent FBAR Submission Procedures

Below is Part 3 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures…more
| Finance & Banking, International Law & Trade, Taxation

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format (which…more
| Finance & Banking, International Law & Trade, Taxation

The IRS’ New 2014 Offshore Voluntary Disclosure Procedures (Part 1)

Last weekend I published the introduction to my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. Below is Part 1 of his 6 part…more
| Civil Procedure, Finance & Banking, International Law & Trade, Taxation

ITINs Will No Longer Expire After 5 Years (Sometimes)

Non-U.S. persons that need a taxpayer identification number must go through the onerous process of obtaining an international taxpayer identification number – commonly referred to as an ITIN…more
| International Law & Trade, Taxation

A Closer Look Into FBAR Late Payment And Interest Penalties Through The Zwerner Settlement – What Were The Penaties And Interest? - How Were They Computed?

While much about the Zwerner case (U.S. v. Zwerner, Case No. 13-22082-CIV, So. Dist. Fl.) has been discussed regarding the FBAR penalties, there has not been much attention paid to the 6% late payment penalty and interest…more
| Finance & Banking, International Law & Trade, Taxation
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Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
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