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The IRS Intends to Audit Hundreds of High-Wealth Taxpayers – Consider Getting Ready Now!

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

Taxation of Virtual Currency Transactions

With the use of virtual currency on the rise, questions emerge as to how virtual currency transactions are taxed. The IRS has issued guidance regarding the tax consequences of such transactions, answering some questions but...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

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