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Protective Refund Claims in Light of Pending Moore v. United States Decision

Taxpayers, including some of the firm’s current and former clients, may be affected by the outcome of the Supreme Court case Moore v. United States, which will address the constitutionality of the Section 965 “Transition...more

Cross-Border Tax-Related COVID-19 Relief

On April 21, 2020, the IRS released a much-awaited package of guidance in the cross-border tax space that provides relief to those impacted by the COVID-19 pandemic. The guidance relates to (1) day-counting for both tax...more

New Rules on Section 83(b) Elections

Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to: - File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more

Proposed Regulations on Foreign-Owned U.S. Disregarded Entities

On May 10, 2016 the Internal Revenue Service (the “IRS”) published proposed regulations that, if finalized, will treat a domestic disregarded entity wholly owned (directly or indirectly) by a foreign person as a corporation...more

IRS Announces Changes to the Offshore Voluntary Disclosure Program

As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more

Who Is a U.S. Person? Disparities Between U.S. Tax and Immigration Law

The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

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