Author Page: Wooyoung Lee — Ruchelman P.L.L.C.

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Altria, C.F.C.’s, Downward Attribution, and the “Real” Congressional Intent

Receipt of a Profits Interest in a Partnership by a Service Provider – Not Taxable

Insights Volume 10 Number 6: Updates & Other Tidbits

Moore v. U.S. – A Case for the Ages to be Decided by Supreme Court

I.R.S. Issues Proposed Regulations on Information Reporting for Digital Assets

U.S. Income Tax Treaty Update

Farhy v. Commr. – The Penalty for Failing to Timely File Form 5471 May Not Be Assessed Administratively

Economic Substance: Views From the U.S., Europe, and the B.V.I., Cayman, and Nevis

Insights Volume 10 Number 2: Updates & Other Tidbits

Tax Considerations for a U.S. Holder Of Bare Legal Title in a Usufruct Arrangement

Is the N.I.I.T. an Income Tax, a Social Security Tax, or Neither? Double Taxation of Income Hangs in the Balance

When It Comes To Penalty Abatement, Is the I.R.S. Offside?

Insights Volume 9 Number 5: Updates & Other Tidbits

Tax 101: U.S. Tax Compliance For Dual Citizen Young Adults

Foreign Tax Credit Regulations: Nexus as the New Credo

New Subpart F and P.F.I.C. Regulations – Ex Uno Plures

The Price is Right: Former I.R.S. Attorney Discusses Information Return and F.B.A.R. Penalties

Goodwill and Mister Donut – A Going Concern?

A C.T.A. of the C.T.A. – A Closer Targeted Analysis of the Corporate Transparency Act

Trusts Under Attack – The Legislative Landscape

Toulouse or Not Toulouse? N.I.I.T.-Picking the Reach of the U.S. Foreign Tax Credit