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- Christmas Comes Early: IRS Announces Penalty Relief for Many 2019 and 2020 Returns (September 2022)
- Foreign Incorporations of U.S. Real Estate: No You Can’t; Yes You Can
- Foreign Incorporations of U.S. Real Estate: No You Can’t; Yes You Can
- GILTI Until Proven Corporate: The CFC Dilemma of Individual U.S. Shareholders
- GILTI Until Proven Corporate: The CFC Dilemma of Individual U.S. Shareholders: New Developments
- Hard Times in the Land of Plenty: Depressed Asset Values Create Opportunities for Wealth Tansfers for Non-U.S. Persons (Part 1) (July 2020)
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- Impulse Buying in the Wake of Tax Reform
- Income Tax Planning for Foreign and Domestic Trusts Holding Beneficiary-Occupied Real Estate (April 2022)
- IRS Announces Closure of 2014 OVDP
- IRS Announces Closure of 2014 OVDP
- IRS Brings the Hammer Down on Those Who Waited
- IRS Provides Reporting and Penalty Relief for Canadian RESP and RDSP Arrangements, As Well As Other Foreign Retirement and Non-Retirement Plan Trusts
- May Guidance for Domestic Trusts Be Drawn From the Final §1.958-1(d) Regulations (June 2022)
- Proposed Regulations Provide Further Guidance to Taxpayers to Qualify for the §199A Deduction for Qualified Business Income
- Proposed Regulations Provide Further Guidance to Taxpayers to Qualify for the §199A Deduction for Qualified Business Income
- Proposed Regulations Provide Further Guidance to Taxpayers to Qualify for the Section 199A Deduction for Qualified Business Income
- Seminars
- Tax Cuts and Jobs Act of 2017 – International Tax Provisions
- Tax Cuts and Jobs Act of 2017 — Business Tax Provisions
- Tax Cuts and Jobs Act of 2017 — Individual Tax Provisions
- Tax Primer for Settlors of Foreign Asset Protection Trusts: Part Two (August 2021)
- Tax Relief for Certain Expatriates: Tax Compliance After the Fact
- Tax Relief Is Not Just for U.S. Persons: The 20% Deduction for Qualified Business Income Under New Code §199A
- Tax Structuring of U.S. Cannabis Companies for Higher Returns and Foreign Investment
- The Common Reporting Standard Comes to Canada (A Complete Analysis)
- The Common Reporting Standard Comes to Canada (A Short Discussion of CRS and What It Means)
- The Corporate Transparency Act: The Final Regulations Provide Limited Guidance With No Surprises (December 2022).
- The Hazards of Common Reporting Standard Advice: Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures
- Third Circuit Affirms Dual Canadian-U.S. Citizen is Liable for FBAR Penalties in ‘United States v. Collins’ as Recklessness is Willful (August 2022)
- What!? They Won’t Accept My Power of Attorney!
- Who Gets to Know and For What Purposes? The Other Side of the Corporate Transparency Act (February 2023)
- Why Partnerships Should Implement the new Centralized Audit Rules
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- A New Era of Compliance Comes Closer: Regulations Proposed for Implementation of Corporate Transparency Act (January 2021)
- Act Now Before This Valuable Estate Tax Saving Opportunity Expires (August 17, 2020)
- American Recovery and Reinvestment Tax Act of 2009
- American Taxpayer Relief Act of 2012 (Article Version)
- Common Sense Thoughts on Asset Protection
- Expatriation: How to Leave the U.S. Tax System Forever
- Hard Times in the Land of Plenty: Depressed Asset Values Create Opportunities for Wealth Transfers for U.S. Persons (Part 2) (September 2020)
- How Will They Catch Me? Let Me Count the Ways (Part One)
- How Will They Catch Me? Let Me Count the Ways (Part Two)
- Is the IRS ending its Streamlined Filing Compliance Procedures? (August 3, 2020)
- Look Before You Leap: When Renouncing U.S. Citizenship May Not Be a Good Idea
- Offshore Voluntary Disclosure Program Round Four: IRS Announces Further Changes To Encourage Broader Compliance
- Tax Cuts and Jobs Act of 2017 – Individual Tax Provision
- Tax Planning and Compliance for Settlors of Foreign Asset Protection Trusts, Part One (July 2021)
- The §385 Debt Equity Regulations: Who Got a Pass and Who Should Worry (December 2020)
- The Corporate Transparency Act Will Change the Way You Practice
- The Curtain Is Descending on the Golden Age of U.S. Estate Planning: Use Existing Opportunities Before the Next Act Starts (October 2021)
- The Exit Tax’s Inconsistent Treatment of Trusts (November 2020)
- Twenty-One Years Is Not Enough
- United States v. Boyd: Ninth Circuit Sides With the Taxpayer for Single Late Penalty on FBAR Reporting Multiple Foreign Accounts (May 2021)
- We May Not Know Who You Are or Where You Live, But We Intend to Find Out: The Corporate Transparency Act of 2020 (March 2021)
- Wonderland Redux: The Meaning of ‘Willful’
- New 2014 Offshore Voluntary Disclosure Program Announced
- FATCA Foreign Account Tax Compliance Act
- Voluntary Disclosures of Foreign Accounts and Other Offshore Assets
- Planning Opportunities In The American Taxpayer Relief Act Of 2012
- 2012 Offshore Voluntary Disclosure Program Issues And Opportunities
- Trust Quarterly Review: Advising Us Citizens And Long Term Residents On Expatriating
- Americans In Canada An Amnesty With Broad Appeal Canadian Tax Focus
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- American Taxpayer Relief Act For 2012 Old Opportunities For Tax Planning Made Permanent Or Extended; New Opporunities Created
- U.S. Citizens with Unpaid Tax Liabilities May Soon Kiss Their Passports Goodbye
- Estate Planning Newsletter
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- Advising Us Citizens And Long Term Residents On Expatriating
- 2011 Offshore Voluntary Disclosure Initiative
- American Recovery And Reinvestment Tax Act Of 2009
- Employment Tax Obligations Of Single Member Llcs
- Advising Clients On Expatriating
- Considerations in Relying On CLN as an Alternative to The OVDP and SFOP
- Financial Account Reporting Issues For Us Persons
- Gulf Opportunity Zone Act Of 2005
- Internal Revenue Service Program For Voluntary Disclosure Of Offshore Investments Closes September 23 2009
- Internal Revenue Service Treating Non Us Mutual Funds As Pfics
- Irs Attacks Undisclosed Foreign Accounts And Investments
- Planning For Ownership Of Us Real Estate
- Small Business Jobs Act Of 2010
- Tax Relief And Health Care Act Of 2006
- Tax Relief Unemployment Insurance Re Authorization Job Creation Act Of 2010
- The American Jobs Creation Act Of 2004
- United States Expatriation Tax Reform
- Year End Tax Planning