Taxation

Taxation

Tax Alert: New Partnership Audit Regime – Effective January 1, 2018

On June 13, 2017, the Treasury Department republished Proposed Treasury Regulations regarding the new partnership audit regime enacted as part of the Bipartisan Budget Act of 2015.  Generally, the new partnership audit rules will be effective January 1, 2018. As a result of the new partnership audit regime: (1) individuals and/or entities that were formerly […]

Taxation

2016 Foreign Bank Account Reports: New Filing Deadline

The U.S. government continues to pursue aggressively individuals and businesses for the failure to report foreign accounts and other non-U.S. assets. In particular, and with limited exceptions, all U.S. individuals and entities that own, control and/or have signature authority over foreign bank accounts must disclose annually to the U.S. Department of Treasury the existence of […]

Taxation and Trust & Estate Litigation

Pre-immigration and Non-U.S. Resident Planning

Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for international tax purposes is a term of art and complex. This planning should be done in advance to […]

Taxation and Trusts & Estates

Important news for family-held businesses: IRS proposes imminent changes in family valuation discounts

On August 2, 2016, the Treasury Department issued Proposed Regulations to Section 2704 of the Internal Revenue Code. These proposed regulations are directed at family controlled entities (many of which hold operating businesses and/or real estate), including corporations, partnerships and limited liability companies. These regulations, if finalized, will substantially limit or eliminate the ability to […]