Articles & Publications
Christmas Comes Early: IRS Announces Penalty Relief for Many 2019 and 2020 Returns (September 2022)
May Guidance for Domestic Trusts Be Drawn From the Final §1.958-1(d) Regulations (June 2022)
The Corporate Transparency Act Will Change the Way You Practice
Tax Primer for Settlors of Foreign Asset Protection Trusts: Part Two (August 2021)
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 Exit Tax’s Inconsistent Treatment of Trusts (November 2020)
Act Now Before This Valuable Estate Tax Saving Opportunity Expires (August 17, 2020)
Is the IRS ending it’s Streamlined Filing Compliance Procedures? (August 3, 2020)
Foreign Incorporations of U.S. Real Estate: No You Can’t; Yes You Can (January 10, 2020)
Tax Relief for Certain Expatriates: Tax Compliance After the Fact (November 8, 2019)
What!? They Won’t Accept My Power of Attorney!
Tax Structuring of U.S. Cannabis Companies for Higher Returns and Foreign Investment (May 10, 2019)
GILTI Until Proven Corporate: The CFC Dilemma of Individual U.S. Shareholders (March 1, 2019)
IRS Brings the Hammer Down on Those Who Waited (January 4, 2019)
Wonderland Redux: The Meaning of ‘Willful’ (September 14, 2018)
Tax Cuts and Jobs Act of 2017 – International Tax Provisions (September 2018)
Impulse Buying in the Wake of Tax Reform (July 13, 2018)
Tax Cuts and Jobs Act of 2017 — Business Tax Provisions (August 2018)
Tax Cuts and Jobs Act of 2017 — Individual Tax Provisions (July 2018)
IRS Announces Closure of 2014 OVDP (May 11, 2018)
Why Partnerships Should Implement the new Centralized Audit Rules
The Common Reporting Standard Comes to Canada (A Complete Analysis)
How Will They Catch Me? Let Me Count the Ways (Part Two) (June 9, 2017)
How Will They Catch Me? Let Me Count the Ways (May 12, 2017) (Part One)
Look Before You Leap: When Renouncing U.S. Citizenship May Not Be a Good Idea (May 18, 2017)
Planning for the Use of the US as a Financial Haven—Part One (November 11, 2016)
Planning for Use of US as Financial Haven—Part Two (December 9, 2016)
Whose Trust is It Anyway (October 14, 2016)
U.S. Gift, Estate, and Generation-Skipping Tax Planning for Cross-Border Couples (June 10, 2016)
Considerations in Relying On CLN as an Alternative to The OVDP and SFOP (March 11, 2016)
U.S. Citizens with Unpaid Tax Liabilities May Soon Kiss Their Passports Goodbye (December 4, 2015)
New 2014 Offshore Voluntary Disclosure Program Announced (June 19, 2014)
Voluntary Disclosures of Foreign Accounts and Other Offshore Assets (September 1, 2014)
Americans in Canada: An Amnesty With Broad Appeal (August 2012)
Financial Account Reporting Issues for US Persons (June 21, 2011)
Planning for Ownership of U.S. Real Estate (February 14, 2011)
Advising U.S. Citizens and Long-Term Residents On Expatriating (February 11, 2011)
2011 Offshore Voluntary Disclosure Initiative (February 11, 2011)
Year-End Tax Planning (December 23, 2010)
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 (September 2009)
United States Expatriation Tax Reform (November 2008)
Employment Tax Obligations of Single Member LLCs
Tax Relief and Health Care Act of 2006 (June 2007)
Gulf Opportunity Zone Act of 2005
The American Jobs Creation Act of 2004 (April 2005)