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

Foreign Financial Asset Reporting - Coming Soon to a Domestic Entity Near You

When Form 8938 reporting for foreign financial assets of U.S. taxpayers was first imposed a few years, only U.S. individuals were subject to it. The IRS has now issued final regulations that will commence reporting by domestic…more
| Business Organizations, Finance & Banking, International Law & Trade, Taxation, Wills, Trusts, & Estate Planning

Applicable Federal Rates - May 2016

Please see charts below for more information…more
| Taxation

Post-Death Action Reduced Amount of Estate Tax Charitable Deduction

Decedent died and left a majority stake in a real property management corporation to a private foundation. The estate tax value of the stock was $14.182M. After the decedent’s death, but before the stock was transferred to…more
| Nonprofit Law, Taxation, Wills, Trusts, & Estate Planning

New Regulations Issued to Expand the Reach of Anti-Inversion Rules

Code Section 7874 seeks to remove the U.S. tax benefits that can apply by inserting a non-U.S. holding company into the ownership structure of businesses formerly conducted through a U.S. holding company. This is a big political…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

The IRS Is Looking to Recharacterize Related Party Debt as Equity Simply for Failing to Meet on a Timely Basis New Contemporaneous Written Documentation Requirements

In the early 1980's, the IRS issued regulations on the question of when loans to corporations would be recharacterized under Code Section 385 as equity. The conversion of purported debt can have significant adverse income tax…more
| Commercial Law & Contracts, Finance & Banking, Taxation

A Death Abroad - Assistance and Issues

The death of a loved one is obviously a difficult time and process for family and friends. If the decedent dies outside of the U.S., the family and friends have the additional burden of dealing with local law and requirements…more
| International Law & Trade, Taxation, Wills, Trusts, & Estate Planning

Out of State Homestead Exemption Voids Florida Exemption [Florida]

Florida exempts a portion of a Florida homestead from ad valorem tax. This could save a taxpayer a few hundred dollars a year. The real economic value to such an exemption is that under Florida's Save our Homes provision, ad…more
| Constitutional Law, Real Estate - Residential, Taxation

Form 8971 Filing Date Extended

The new Form relating to reporting to beneficiaries of estates and the IRS on the tax basis of distributed assets has had its first filing due date extended to June 30, 2016…more
| Taxation, Wills, Trusts, & Estate Planning

Applicable Federal Rates - April 2016

Please see Charts below for more information…more
| Taxation

Income Tax Assessment on Beneficiary Allowed Even Though the Statute of Limitations Had Expired

A recent Tax Court case illustrates how the IRS was able to assess income taxes against two trust beneficiaries even though the statute of limitations for assessment had expired, via the mitigation provisions of the Internal…more
| Taxation, Wills, Trusts, & Estate Planning

IRS Audit Instructions for Outbound Section 482 Transactions

Code Section 482 requires taxpayers that conduct related party sales and transactions to use arms-length pricing. Section 482 particularly applies to international transactions given the possibility to shift taxable income out…more
| Commercial Law & Contracts, International Law & Trade, Taxation

Expatriation Case

Cases on the new expatriation regime under Code Section 877A are few and far between. The Tax Court has now issued an opinion involving a U.S. resident who gave up his green card and the resulting consequences under Code Section…more
| Taxation

New Basis Consistency and Reporting Proposed Regulations - Did the IRS Go Too Far?

The IRS has issued proposed regulations under new Code Sections 1014(f) (relating to requirements that the initial income tax basis of an asset received from a decedent cannot exceed the estate tax basis of that asset) and…more
| Taxation, Wills, Trusts, & Estate Planning

Guardianship Court Permitted to Annul Marriage [Florida]

An incapacitated ward had his rights to contract removed by a guardianship court. The ward thereafter married, without court approval. The marriage was then challenged based on FS 744.3215(2)(a) (2013). That statute provides…more
| Family Law, Taxation

Code Section 752 Liabilities Include Obligations Under Construction Contract

Partners in a partnership receive adjusted basis in their partnership interests for their allocable share of partnership liabilities. Since basis will allow for distributions to be made to partners without gain, losses to be…more
| Commercial Law & Contracts, Construction Law, Taxation
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Boca Raton, Florida 33431, United States

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Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
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