Offices at BETHESDA, VANCOUVER, NEW YORK, and TYSON'S CORNER 301-986-2200 301-986-2200

Articles & Publications

The Exit Tax’s Inconsistent Treatment of Trusts (November 2020)

Hard Times in the Land of Plenty: Depressed Asset Values Create Opportunities for Wealth Transfers for U.S. Persons (Part 2) (September 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)

Hard Times in the Land of Plenty: Depressed Asset Values Create Opportunities for Wealth Tansfers for Non-U.S. Persons (Part 1) (July 2020)

Foreign Incorporations of U.S. Real Estate: No You Can’t; Yes You Can (January 10, 2020)

IRS Provides Reporting and Penalty Relief for Canadian RESP and RDSP Arrangements, As Well As Other Foreign Retirement and Non-Retirement Plan Trusts (May 8, 2020)

The Hazards of Common Reporting Standard Advice: Model Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (March 13, 2020)

Tax Relief for Certain Expatriates: Tax Compliance After the Fact (November 8, 2019)

GILTI Until Proven Corporate: The CFC Dilemma of Individual U.S. Shareholders: New Developments (March 1, 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)

Proposed Regulations Provide Further Guidance to Taxpayers to Qualify for the §199A Deduction for Qualified Business Income (November 9, 2018)

Tax Relief Is Not Just for U.S. Persons: The 20% Deduction for Qualified Business Income Under New Code §199A (March 9, 2018)

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)

Twenty-One Years Is Not Enough: Avoiding Canada’s 21-Year Rule with Trusts for U.S. Beneficiaries (November 10, 2017)

Why Partnerships Should Implement the new Centralized Audit Rules

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) (October 2017)

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)

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] (October 10, 2014)

New 2014 Offshore Voluntary Disclosure Program Announced (June 19, 2014)

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) (May 9, 2014)

Voluntary Disclosures of Foreign Accounts and Other Offshore Assets (September 1, 2014)

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 (January 15, 2013)

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

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)

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

Proposed Regulations Provide Further Guidance to Taxpayers to Qualify for the §199A Deduction for Qualified Business Income