By Kevin Hall and Leigh-Alexandra Basha on Oct 30, 2018
Posted In Tax Reform, Uncategorized
Several changes in tax reform have a disparate impact on non-corporate US shareholders of foreign corporations compared with their corporate counterparts. Many such non-corporate shareholders face an expensive tax increase. They may attempt to mitigate this increase by transferring their shares to a US corporation or making a Section 962 election. This article examines the...
By Andrew R. Roberson, Kevin Spencer and Leigh-Alexandra Basha on Jan 25, 2018
Posted In IRS Guidance, Trial Courts, Uncategorized
On December 13, 2017, the US Tax Court (Tax Court) held that a family office was appropriately treated as a business, and permitted to deduct its expenses pursuant to Internal Revenue Code (Code) Section 162. In Lender Management LLC v. Commissioner, T.C. Memo. 2017-246, the Internal Revenue Service (IRS) argued that the taxpayer’s expenses should...
By Andrew R. Roberson, Jonathan D. Lockhart and Leigh-Alexandra Basha on Aug 10, 2016
Posted In IRS Audits, IRS Guidance, Trial Courts, Uncategorized
The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs in which to report foreign assets and/or income and become compliant with US rules related to the disclosure of foreign assets. One option is the Offshore Voluntary Disclosure Program (OVDP). Another is the Streamlined Filing Compliance Procedures (SFCP). SFCP is further...
By Andrew R. Roberson, Daniel J. Bell, Jonathan D. Lockhart and Leigh-Alexandra Basha on Apr 8, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
On April 3, 2016, the International Consortium of Investigative Journalists (ICIJ) indicated that it acquired sensitive documents that belonged to the Panamanian law firm, Mossack Fonseca & Co., about the offshore holdings of some of the world’s most prominent and wealthy individuals. The leak has received substantial mainstream media coverage due to the identity of...