Latest Publications

Share:

Get Ready: IRS To End OVDP

Recently, I discussed the impact of so-called “soft letters” sent by the IRS to various groups of taxpayers with offshore asset disclosure compliance issues....more

Expect Focus - International - March 2018

Trends Against BITS and Investor State Dispute Resolution - In my first Expect Focus International article (http://bit.ly/2G9Demu), I suggested that investors doing business outside the United States should do so in...more

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

A Day Of Reckoning For Recalcitrant Taxpayers?

Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of...more

How To Manage Foreign Trusts With U.S. Beneficiaries

Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth....more

5 Results
/
View per page
Page: of 1

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.