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Federal Taxation

  • Federal Investigators Increase Scrutiny of Offshore Bank Accounts

    By:
    Alicea Castellanos, CPA, TEP, N.P., and Jack Brister, TEP
    |
    Dec 1, 2016

    Federal watchdogs are demonstrating their renewed focus on the illegal use of offshore bank accounts, as the Department of Justice (DOJ) says it is zeroing in on potential tax evaders. 

  • To Have and to Hold But to Not Be Held Accountable

    By:
    Jacalyn F. Barnett, Esq.
    |
    Nov 1, 2016
    New Year’s Eve is not just a time for fireworks and celebrations—it is also the moment when the IRS determines whether or not you are married. If you are married at the stroke of midnight, the IRS considers you to have been married for the whole year. 

  • Fundamental Tax Reform Is Mostly Dead—but Not Quite

    By:
    Curtis S. Dubay
    |
    Oct 1, 2016

    In the classic children’s movie The Princess Bride, Billy Crystal plays a miracle-performing medicine man. When the hero of the story is brought to him, Crystal’s character says that he is “mostly dead.” That is an apt description of fundamental tax reform’s current state. 

  • Proposed Regulations Under IRC Section 2704

    By:
    Kevin Matz, Esq., CPA, LLM (Taxation)
    |
    Oct 1, 2016

    On Aug. 2, 2016, the U.S. Department of the Treasury and the IRS issued proposed regulations under IRC Section 2704 (the “Proposed Regulations”) that, if enacted in its present form, might significantly curtail the ability of taxpayers to claim valuation discounts for both lack of control and lack of marketability in family-controlled entities. 

  • A Brief Update on Filing Requirements for U.S. Citizens Living Abroad and Resident Aliens in the United States

    By:
    R. John Smith, Esq.
    |
    Oct 1, 2016

    Who has to file Form 1040NR? Form 1040NR may need to be filed if a specified individual is a nonresident alien engaged in a trade or business in the United States, represented a deceased person who would have had to file Form 1040NR, or represented an estate or trust that had to file Form 1040NR. See the form’s instructions for more information.

  • Is It Debt or Equity? A Survey of the Proposed Section 385 Regulations

    By:
    James J. Wienclaw, CPA
    |
    Jul 1, 2016
    The fundamental question investors address when capitalizing a business is how it should be funded—with debt, equity, or a combination of both. Considerations can vary widely depending on the level of risk an investor is willing to take or the desired tax treatment.

  • New Seller Due Diligence Responsibilities After the Midco Cases?

    By:
    Ellen S. Brody, CPA, JD, Esq. and Vivek A. Chandrasekhar, JD, Esq.
    |
    Jul 1, 2016
    In the post-General Utilities world, shareholders have looked to dispose of their interest in C Corporations with appreciated assets in a way that would avoid the double taxation arising on a sale of assets followed by a liquidating distribution to the noncorporate shareholder. 
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