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Articles & Publications

The Common Reporting Standard Comes to Canada

How Will They Catch Me? Let Me Count the Ways (Part Two) [2017-06-09]

How Will They Catch Me? Let Me Count the Ways [2017-05-12] (Part One)

Look Before You Leap: When Renouncing U.S. Citizenship May Not Be a Good Idea [2017-05-18]

Planning for the Use of the US as a Financial Haven—Part One [2016-11-11]

Planning for Use of US as Financial Haven—Part Two [2016-12-9]

Whose Trust is It Anyway [2016-10-14]

U.S. Gift, Estate, and Generation-Skipping Tax Planning for Cross-Border Couples [2016-06-10]

Considerations in Relying On CLN as an Alternative to The OVDP and SFOP [2015-11-16]

U.S. Citizens with Unpaid Tax Liabilities May Soon Kiss Their Passports Goodbye [2015-12-04]

Offshore Voluntary Disclosure Program Round Four: IRS Announces Further Changes to Encourage Broader Compliance (as published in BNA Tax Management International Journal) [Vol. 43, no. 604, 2014-10-10]

New 2014 Offshore Voluntary Disclosure Program Announced [2014-06-19]

How to Leave the U.S. Tax System Forever” 43 Bloomberg BNA Tax Management International Journal 255 (May 9, 2014)

FATCA, the U.S.-Canada IGA, and Trusts (as published in BNA Tax Management International Journal) [Vol. 43, no. 255, 2014-05-09]

Voluntary Disclosures of Foreign Accounts and Other Offshore Assets [2014-09-01]

Planning Opportunities in the American Taxpayer Relief Act of 2012” American Law Institute The Practical Tax Lawyer (Spring 2013)

American Tax Payer Relief Act of 2012: Old Opportunities For Tax Planning Made Permanent  or Extended; New Opportunities Created [2013-15-01]

2012 Offshore Voluntary Disclosure Program; Issues and Opportunities (as published in BNA Tax Management International Journal) [Vol. 41, No. 10, 2012-10-12]

Americans in Canada: An Amnesty With Broad Appeal [2012-8-01]

Americans in Canada: The End of Amnesty [2011-11-17]

Financial Account Reporting Issues for US Persons [2011-06-21]

Planning for Ownership of U.S. Real Estate [2011-02-14]

Advising U.S. Citizens and Long-Term Residents On Expatriating [2011-02-11]

2011 Offshore Voluntary Disclosure Initiative [2011-02-11]

Year-End Tax Planning [2010-12-23]

Tax Relief, Unemployment Insurance Re-authorization, Job Creation Act of 2010

Small Business Jobs Act of 2010

Internal Revenue Service Treating Non-U.S. Mutual Funds as PFICs

American Recovery and Reinvestment Tax Act of 2009

United States Expatriation Tax Reform

Employment Tax Obligations of Single Member LLCs

Tax Relief and Health Care Act of 2006

Gulf Opportunity Zone Act of 2005

The American Jobs Creation Act of 2004

Internal Revenue Service Program for Voluntary Disclosure of Offshore Investments Closes September 23, 2009

A Recap – The American Recovery and Reinvestment Tax Act of 2009” Taxes – The Tax Magazine (September 2009)

Common Sense Thoughts on Asset Protection Planning” 5 Journal of Asset Protection Planning No. 5 (May/June 2000)

IRS Attacks Undisclosed Foreign Accounts and Investments