On July 10, 2023, California Governor Gavin Newsom signed into law S.B. 131, which included a provision targeting the California state income tax treatment of incomplete gift non-grantor trusts ("INGs"). Under the prior law,...more
The Internal Revenue Service (IRS), through its Large Business and International Division (LB&I), has created a Global High Wealth (GHW) program to audit hundreds of high-wealth taxpayers who own assets or earnings in the...more
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” or the “Act”), signed into law on March 27, 2020, is a stimulus package that aims to provide liquidity to many Americans – by either giving cash or...more
3/31/2020
/ busin ,
Business Closures ,
Business Interruption ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Loans ,
Financial Stimulus ,
Paycheck Protection Program (PPP) ,
Payroll Taxes ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business ,
Tax Relief ,
Unemployment Insurance
Private credit appears to be the dominating trend throughout emerging business markets. Businesses seeking to raise capital are finding private investors who, unsurprisingly, are looking to maximize yield, while at the same...more
The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more
3/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
Whether it be a Hollywood mogul, a renowned politician or a formerly respected executive, it is clear from the Me Too and Time’s Up movements that the voices seeking and stands taken to uncover and prevent sexual harassment...more
1/8/2018
/ Confidentiality Agreements ,
Employer Liability Issues ,
New Legislation ,
Non-Disclosure Agreement ,
Settlement ,
Sexual Harassment ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The latest edition of Global Connection offers insight into a potential money laundering crackdown in the real estate sector, information on the Federal Trade Commission’s approach to data breach investigations and a legal...more
Any U.S. person with a foreign affiliate is required to file the 2014 Form BE-10, Benchmark Survey of U.S. Direct Investment Abroad by June 30, 2015 or face civil penalties between $2,500 and $25,000. Further, a willful...more
6/6/2015
/ Benchmarks ,
Civil Monetary Penalty ,
Compliance ,
Criminal Penalties ,
Filing Requirements ,
Foreign Affiliates ,
Foreign Direct Investment ,
Foreign Investment ,
Form BE-10 ,
Internal Revenue Code (IRC) ,
Popular ,
Real Estate Investments
On June 18, 2014, the IRS made significant changes to the procedures pursuant to which U.S. Persons can disclose any failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), and/or an international...more
You know what’s better than earning portfolio interest? Nothing. OK, that may be an overstatement. But for non-U.S. lenders looking to earn a return on their U.S.-based investments, with respect to paying U.S. taxes, that’s...more
On October 4, 2011, we reported on the Voluntary Classification Settlement Program (VCSP), a program in which the IRS permits employers to prospectively reclassify workers as employees in exchange for limited federal...more