Charles (Chuck) Rubin
Gutter Chaves Josepher Rubin Forman Fleisher P.A.

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2101 NW Corporate Blvd.
Suite 107
Boca Raton, Florida 33431, United States
Phone: 561-998-7847
Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
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IRS Provides Some Relief for Post-Divorce Grantor Trust Rule Issues

During happy days, one spouse (call him or her the “Donor Spouse”) sets up an irrevocable trust for the benefit of the other spouse (call him or her the “Donee Spouse”)…more
 /  Taxation

IRS Guidance Issued on New Interest Stripping Rules

The Tax Cuts and Jobs Act substantially modified the interest stripping rules of Code §163(j). In a recent IRS notice, the IRS provided guidance on some of the provisions of the revised limitation and what new regulations will…more
 /  Taxation

Offshore Voluntary Disclosure Program (OVDP) Closing in September

The OVDP commenced in 2009, and provided a mechanism for U.S. taxpayers who had not complied with various non-U.S. information disclosure and tax payments to square up with the IRS without risk of criminal prosecution, but at…more
 /  Taxation

Applicable Federal Rates - April 2018

Please see full Charts below for more information…more
 /  Taxation

Key Federal Inflation-Adjusted Amounts for 2018

In Rev.Proc. 2018-18, the IRS has released various tax rates, brackets, and threshold amounts for 2018, incorporating inflation adjustments and the new tax act…more
 /  Taxation

State Asset Protection Trusts Take Another Hit

Numerous states have statutes that allow for the creation of self-settled discretionary trusts that are protected from claims of the settlor while allowing the settlor to be a discretionary beneficiary. Such trusts are likely…more
 /  Taxation

Good News on Florida Homestead Protections

I had previously written that as part of the 20 year revision process, a proposal to reduce Florida's constitutional homestead protection against claims for creditors was advancing…more
 /  Taxation

High Tax Kickout from GILTI Inclusion for CFC's May Be Too Restrictive

The new Tax Act added new Code Section 951A. This provision creates a new class of income of a CFC that is taxed currently to U.S. shareholders. That class is "global intangible low-taxed income" or "GILTI."…more
 /  Taxation

Updated Historical Federal Transfer Tax Rates, Exemptions, and Related Information Table

I have updated this table to include 2018 data based on inflation adjustments and changes in the 2017 Tax Act. The $11,180,000 exemption and exemption equivalent amounts for estate, gift and GST tax are not yet out, so estimates…more
 /  Taxation

No Homestead Treatment for Property Owned by a Corporation [Florida]

In a recent case, residential property was owned by a corporation. The sole shareholder and president of the corporation resided on the property, and the corporation had attempted to convey the residence to the shareholder, but…more
 /  Taxation

When a Nightclub is Not a Business

Under Code §183(b), a taxpayer’s activity that is not engaged in for profit gives rise to deductions only to the extent of income. No excess deductions arise that can be used to offset other income, and no net operating losses…more
 /  Taxation

The U.S. Will Now Bar Tax Delinquents from Traveling Abroad

I wrote back in 2015 here about new legislation that gave power to the Secretary of State to deny, revoke or limit the passport of persons with delinquent taxes. Code §7345 provides that the Commissioner of the IRS will provide…more
 /  International Law & Trade, Taxation

Applicable Federal Rates – February 2018

Please see charts below for more information. …more
 /  Taxation

Obscure Provision of New Tax Act Complicates Testamentary Tax Planning for Nonresidents with U.S. Beneficiaries

Nonresidents with a significant portfolio of U.S. stocks typically use a non-U.S. corporation to hold their portfolio. This is because U.S. stocks are generally subject to U.S. estate taxes at the death of their owner, and…more
 /  Commercial Law & Contracts, Elections & Politics, International Law & Trade, Taxation

Review/Summary of International Provisions of the New Tax Act

On December 20, 2017, Congress passed H.R.1, known as the “Tax Cuts and Jobs Act” (referred to in this letter as the “Act”), which was signed into law by President Donald Trump on December 22, 2017. The Act makes widespread…more
 /  Commercial Law & Contracts, Elections & Politics, International Law & Trade, Taxation
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