Leigh-Alexandra Basha Leigh-Alexandra Basha

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Leigh-Alexandra Basha focuses her practice on domestic and international estate and tax planning. She counsels an affluent international client base on a wide range of sophisticated matters, including estate and trust administration, family wealth preservation, tax compliance, as well as business succession, expatriation and pre-immigration planning. Leigh is head of the Firm’s Washington, DC, Private Client Practice Group. Read Leigh-Alexandra Basha's full bio.

Bring That CFC on Home: Domesticating Individually-Owned CFCs After Tax Reform


By and 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...

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Court Rules That a Family Office Is a Business!


By , and 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...

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Offshore Voluntary Disclosure Update


By , and 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...

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Release of “Panama Papers” May Encourage New Wave of OVDP Submissions


By , , and 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...

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