Applicable Federal Rates – June 2013. See charts below for more information…more
My partner, Rick Josepher, was involved through the Florida Bar in a major update to Florida’s limited liability company provisions which were recently enacted into law. The following is a summary regarding the new provisions…more
Most states will suspend or involuntarily dissolve a corporation if it does not pay local taxes or fees. Such suspensions and dissolutions can typically be reversed after the corporation files to be restored and pays any back…more
The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal…more
If a taxpayer does not file a tax return, the statute of limitations for most federal taxes never commences. Thus, in theory, the IRS can go back as many years it wants to such an “open” year to audit and assess tax…more
In a recent report, the General Accounting Office (GAO) encourages the IRS to do more to uncover and pursue taxpayers who made quiet disclosures in regard to their non-U.S. accounts…more
Foreign asset protection trusts are often established by U.S. persons to shield their assets from creditors. Typically, assets transferred to the trust can be paid to or applied for the benefit of the U.S. grantor(s) and their…more
79 year-old Mary Estelle Curran received good new when she was sentenced for criminal tax evasion and failing to file reports of foreign bank accounts on UBS Swiss accounts she inherited from her husband…more
Please see full Applicable Federal Rates chart below for the May 2013 rates…more
Last week, the ACLU created a stir when it suggested that the IRS may be reading taxpayers’ emails without obtaining a search warrant. At least at some point in time in the past, according to the IRS’ 2009 “Search Warrant…more
Taxpayers that own rental real estate property will often want to qualify as “real estate professionals” under Section 469 (the “passive loss rules”). If they do that, their losses from their real estate activities can be used…more
Late last year, Congress and the President agreed to "permanent" transfer tax revisions that set the unified credit equivalent exemption at $5.25 million in 2013, indexed it for inflation, and set the maximum rate at 40%. At…more
If a taxpayer owns appreciated property and transferors it to another, and that successor owner sells the property, the gain from the sale is reportable by the successor owner, not the donor. However, if the gift occurs too…more
Code §2703 severely restricts the ability of a buy-sell agreement to control estate tax values in a closely held entity. A recent private letter ruling reminds us that older agreements are not subject to Code §2703…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 by…more
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