News & Analysis as of

Tax Planning

Section 7C

by Hogan Lovells on

Raising the red flag on low interest and interest free loans to trusts - Over the years, trusts have consistently proved to be a reliable and attractive vehicle for many, offering flexibility and benefits with regard to...more

Does investing in a PFIC make sense given FATCA reporting?

by Foodman CPAs & Advisors on

Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more

Hurricanes, Displacement And The Effect On Domicile

by Murtha Cullina on

In the span of three weeks, Hurricanes Harvey and Irma descended upon the southern United States causing mass evacuations, heroic rescues, and catastrophic damage, particularly in Texas and in Florida. As a result, many...more

Residency Tax Planning for Noncitizens Under IRS Publication 519

Noncitizens who intend to become residents of the United States are often well-advised to receive foreign-source earned income and recognize foreign-source capital gains before establishing residency in the United States. In...more

"Money" Mayweather’s $22 Million Tax Problem

by Moskowitz LLP on

Floyd "Money" Mayweather certainly lives up to his nickname – the undefeated boxer is expected to cash in as much as $350 million for his recent win against Irish UFC fighter Conor McGregor....more

Tax Court Decides First Micro Captive Case

On August 21, 2017, the Tax Court issued its opinion in two companion cases Benyamin Avrahami and Orna Avrahami v. Commissioner, and Feedback Insurance Company, Ltd. v. Commissioner, 149 T.C. No. 7, holding against the...more

The Importance of Timely Electing Your Foreign Earned Income Exclusion

Life as an American living abroad can conjure idyllic notions of painting en plein air in Paris or negotiating a last minute deal in Brussels. Not so idyllic, however, is the reality of filing U.S. tax returns from overseas....more

New Cases Provide Mixed Messages to Conservation Easement Donors

Fifth Circuit encourages flexibility for conservation easement deductions in Bosque Mountain Ranch, while Tax Court makes it difficult for farmers in Rutkoske. Two important conservation easement opinions were handed down...more

The Distinction Between Partnership Debt and Partnership Equity

by White & Case LLP on

Insights and strategies in a rapidly changing area for taxpayers who want to be characterized as partners for tax purposes but want an investment that economically is very close to debt. Much ink has been spilled on the...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

The Malta Pension Plan – A Supercharged, Cross-Border Roth IRA

by Bilzin Sumberg on

In the cross border setting, two of the principal goals in international tax planning are (i) deferral of income earned offshore and (ii) the tax efficient repatriation of foreign profits at low or zero tax rates in the...more

Unexpected Risks of Early Exercise Incentive Stock Options

by Dorsey & Whitney LLP on

Canadian companies and their outside counsel occasionally ask about the ability to grant early exercise incentive stock options (“ISOs”) to limit the impact of the U.S. alternative minimum tax (“AMT”) to their U.S. employees....more

ALJ Forces Combination of Hedge Fund Group in New York City - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return for New York City tax purposes. However, the administrative law judge (ALJ)...more

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

The Federal Government takes aim at private corporations and their shareholders

by Dentons on

On July 18, 2017, the Federal Government released a package of tax measures aimed to “improve fairness”, “close loopholes” and limit tax planning strategies that involve the use of private corporations. The suite of measures...more

Three Fund Issues That Can Unexpectedly Impact Portfolio Company Investments

by Latham & Watkins LLP on

Increasingly complex fund structures and documentation mean that analysing how potential portfolio acquisitions interact with the fund at the top of any deal structure is more important now than ever. Investor Excuse...more

BEWARE! Impact of New Tax Rules on Your Family Limited Partnership

by Strasburger & Price, LLP on

Family limited partnerships (“FLPs”) are a common estate planning technique. They permit centralized asset management, provide liability protection, and create a mechanism by which one generation can transfer wealth to the...more

IRS Grants Taxpayers Two-Year Window to File Portability Election

by Bryan Cave on

In a long-awaited move, the IRS announced recently that taxpayers will now have at least two years to file an estate tax return to elect portability of a decedent’s unused estate tax exemption to the decedent’s surviving...more

Update to Guide on U.S. Taxation of Nonresident Aliens

by Charles (Chuck) Rubin on

I first wrote a simplified guide to U.S. taxation of nonresident aliens before the Internet and emails. The first few editions were printed and mailed out to persons on our firm's mailing list. Eventually, I circulated it by...more

Unsurprising Façade Easement Holding by Tax Court: Conservation Easement Must Be Recorded to Qualify for Deduction

Those familiar with conservation easements know that, to qualify for a federal tax deduction, a conservation easement must meet several rigorous requirements found in Internal Revenue Code Section 170 and Section 1.170A-14 of...more

Deferring Taxes but Keeping the Cash

by Slim Ventures LLC on

In recent years, many public and private companies have been able to defer capital gains tax on appreciated assets while keeping up to 95% of the proceeds (versus 65%-75% in paying taxes). ...more

Inbound and Outbound U.S. Tax Planning - What's Left After the MLI?

by Bilzin Sumberg on

On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place. ...more

Severance Agreements – Three Tax Traps for the Unwary

by Foley & Lardner LLP on

Severance agreements – especially severance agreements for terminating executives – are ripe with potential tax planning challenges and opportunities....more

ESOP Trends in the Marketplace

by McDermott Will & Emery on

Over the years, employee stock ownership plans (ESOP) have evolved in many ways. Currently, ESOP transactions began to resemble traditional M&A transactions including financial structures, warrants and market rate sub-debt....more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

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