HIDE

Other Publications

Insights

Publications

Insights Vol. 4 No. 11: Updates & Other Tidbits

Insights Vol. 4 No. 11: Updates & Other Tidbits

This month, Sheryl Shah and Nina Krauthamer look briefly at two I.R.S. actions: (i) the roll out of a long-awaited passport denial program and (ii) the end of favorable rulings on certain worthless stock deductions and spinoffs.

Read More

Art and the Estate Part II – Nonresidents

Art and the Estate Part II – Nonresidents

Foreign persons owning artwork physically located in the U.S. must be mindful of special income, estate, and gift taxes associated with that ownership.   In the second of a series, Rusudan Shervashidze and Nina Krauthamer look at issues such as use tax, which is the U.S. equivalent of a reverse charge of V.A.T., estate tax, and gift tax.

Read More

Employment Tax Basics and Paths to Compliance

Employment Tax Basics and Paths to Compliance

 When a company expands across a border, it faces a complex web of employment-related taxes.  Penalties for failure to properly comply with these rules can be severe.  Fanny Karaman looks at the U.S. rules that are applicable to the payment of wages and bonuses, the penalties that can be imposed on compliance failures, and the procedures that are available to cure errors.  The rules are not straightforward, guidance is often minimal, and an experienced advisor is extremely valuable.

Read More

Texas District Court on Anti-Inversion Legislation – One Down but Not Out

Texas District Court on Anti-Inversion Legislation – One Down but Not Out

The final months of the Obama administration saw the hurried adoption of temporary regulations in an attempt to extend its tax policy into the current administration.  However, reliance on temporary regulations that are adopted without a public comment period may have been misguided.  In October, a U.S. District Court struck down a provision under temporary anti-inversion regulations for violating the required notice and comment period under the Administrative Procedure Act.  Beate Erwin and Sheryl Shah explain the web of issues involved in the decision.

Read More

Anti-Inversion Rules Are Not Just for Mega-Mergers – Private Client Advisors Take Note

Anti-Inversion Rules Are Not Just for Mega-Mergers – Private Client Advisors Take Note

The U.S. has rules that attack inversion transactions, wherein U.S.-based multinationals effectively move tax residence to low-tax jurisdictions.  If successful, these moves allow for tax-free repatriation of offshore profits to the inverted parent company based outside the U.S.  However, the scope of the anti-inversion rules is broad and can also affect non-citizen, nonresident individuals who directly own shares of private U.S. corporations.  Attempts to place those shares under a foreign holding company as an estate planning tool may find that the exercise is all for naught once the anti-inversion rules are applied.  Elizabeth V. Zanet, Galia Antebi, and Stanley C. Ruchelman discuss the hidden reach of the anti-inversion rules to private structures.

Read More