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New California Law Attacks NINGs and DINGs

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

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

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

To Disclose or Not to Disclose, That Will Be the Question

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

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