This presentation discusses the basics of a controlled foreign corporation and the complications of de-controlling it with respect to Proposed Regulation 385, local country constraints, and the impact of section…
Severiano Ortiz participates in drafting Comments on Guidance under Section 2801, regarding the imposition of tax on certain gifts and bequests from covered expatriates, on behalf of the American Bar…
This panel addresses the basics of what is known in the international tax planning community as inbound tax planning, meaning tax planning for money or business flowing into the U.S.:…
Final Regulation (T.D. 9752), was published and became effective February 23, 2016. This final regulation adopts the 2011 Proposed Regulation § 1.6038D-6, with certain modifications. It establishes when a domestic…
This program examines the concept of “residence” for alien individuals, including the variety of statutory and regulatory rules that apply for income tax, estate and gift tax and other purposes,…
This panel addresses the basics of what is known in the international tax planning community as inbound tax planning: When does a non-U.S. person become subject to U.S. taxation? What…
Absent any IRS guidance on a HUF, how should practitioners counsel their clients in light of the increased information sharing due to FATCA and inter-governmental agreements? This panel explores the…
This panel addresses several recent developments in international tax, with a focus on issues that young lawyers and new practitioners are likely to encounter in practice. The panelists discuss a…
Learn about the common pitfalls practitioners face in completing the required forms, when a mistake requires more than simply ling a delinquent form, how to choose the right type of…
Final regulation (T.D. 9706), was published and became effective December 12, 2014. This final regulation adopts the 2011 temporary regulations as final regulations, with certain modifications. It did not yet,…
