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Foreign Corporations Estate Tax

Strafford

[Webinar] Tax Treatment of Leveraged Blockers Used by Foreign Investors: Recent IRS Guidance, Deal Structures, Tax Planning - June...

Strafford on

This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more

Rivkin Radler LLP

Foreign Individuals Holding U.S. Real Property, or Left Holding the Bag?

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There have been some interesting developments of late with respect to the ownership of real property in parts of the English-speaking world. For example, Canada has imposed a temporary ban on the purchase of such property by...more

Moritt Hock & Hamroff LLP

Basic U.S. Tax Considerations In Investing In U.S Real Estate

Background. Whether your1 investment in U.S. real estate is intended for personal use – that is, the property will be used by you and your family exclusively as a personal residence (perhaps also made available on occasion to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Cross-Border Estate Planning

The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more

BCLP

US “TCJ Act” Tightening of CFC Rules Eliminates Common Approach To Post-Death Avoidance Of US Beneficiary Taxation

BCLP on

On December 22, 2017, President Trump signed into law H.R. 1 (Pub. L. No. 115-97), known as the Tax Cuts and Jobs Act (the “Act”). The Act is the first major overhaul of the Internal Revenue Code (the “Code”) in more than 30...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

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President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

A&O Shearman

House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

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On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released its plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings,...more

Holland & Knight LLP

A Comparison of the House and Senate Tax Bills

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It has been a busy week in Washington, D.C., as Congress works its way through tax reform. The House Ways and Means Committee completed its "markup" of the House bill this week, paving the way for a floor vote on the measure...more

Proskauer - Tax Talks

The Tax Cuts and Jobs Act

Proskauer - Tax Talks on

Today, the Republicans in the U.S. House of Representatives released their long-anticipated tax reform bill, entitled the “Tax Cuts and Jobs Act”. While there have been multiple statements from the Republican majority in the...more

Lowndes

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Lowndes on

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

Lowndes

IRS Identifies 8 Burdensome Regulations for Reform

Lowndes on

Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more

Holland & Knight LLP

Treasury Dept. Identifies 8 "Significant Tax Regulations" for Review to Reduce Burden

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The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Pillsbury Winthrop Shaw Pittman LLP

New York State Department of Taxation and Finance To Disregard Single-Member LLC Interests for New York Estate Tax

In a recent New York State Advisory Opinion, the New York State Department of Taxation and Finance advised that a federal income tax entity classification election could impact whether property held by a nonresident through a...more

Gerald Nowotny - Law Office of Gerald R....

Mi Casa es Su Casa! - Planning Considerations Non-Resident Aliens Purchasing a Home in America

Overview - In spite of our many problems as a nation, the quality of life and level of economic opportunity as well as the overall respect for the rule of law, places the United States in a very unique position when...more

Burns & Levinson LLP

United States v. Windsor: Tax Issues

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Although the decision of the United States Supreme Court in United States v. Windsor invalidating much of the Defense of Marriage Act (DOMA) affects at most approximately 20% of the population of the United States, it has...more

Dechert LLP

American Taxpayer Relief Act of 2012 Approved by Congress and Signed by the President

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Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more

Eversheds Sutherland (US) LLP

Legal Alert: The Cliff-Hanger (Chapter One) is Over: Highlights of the American Taxpayer Relief Act of 2012

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more

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