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Presentations

U.S. Citizens as Shareholders of Canadian Companies – Impact on Reorganizations and Other Canadian Tax Consequences

U.S. Citizens as Shareholders of Canadian Companies – Impact on Reorganizations and Other Canadian Tax Consequences

First presented at the Canadian Tax Foundation’s 68th Annual Tax Conference (2016) in Calgary, AB.

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U.S. Tax Update

U.S. Estate and Gift Tax Concepts

Partnerships: The Fundamentals

T & E Planning Tidbits from Canada and France

E.U. State Aid

FATCA’s Expanding Global Reach: A Concern for Big and Small

Partnerships: The Fundamentals

Woops, My U.S. Real Estate is in a U.S. Corporation: How to Make the Most of a Bad Situation

The Multilateral Instrument

Buying U.S. Real Estate

Overview of U.S. Taxation of Cross Border Investments & Operations

Update on FATCA & OVDI

On November 2, 2015, Galia Antebi presented “An Update of F.A.T.C.A.” at the 2015 Advanced Tax Institute, sponsored by the Maryland State Bar Association and the Maryland Association of C.P.A.’s, in Baltimore, Maryland.

The discussion covered an overview of F.A.T.C.A. legislation, the current status of exchanges of financial information between I.G.A. partner countries, and other hot topics, including new account opening procedures in countries that have signed a Model 1 I.G.A.

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Foreign Persons Investing In U.S. Real Estate: Partnership and Other Structures, Opportunities and Traps

Philip R. Hirschfeld presented on the panel “Foreign Persons Investing In U.S. Real Estate: Partnership And Other Structures, Opportunities and Traps” as part of the NYU Advanced Summer Institute in Taxation. The summer institute is offered annually by NYU’s Advanced International Tax Institute. Mr. Hirschfeld’s presentation focused on ways to structure a non-U.S. person’s investment in U.S. real estate in ways that minimize taxation. Investments in mortgage debt securities, partnerships, L.L.C.’s, and R.E.I.T.’s were covered.

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Tax Planning for U.S. persons in Europe – Residency in Europe, Disclosure, Expatriation

Stanley C. Ruchelman and Beate Erwin attended the 2015 ITSG European Conference in Madrid, Spain.

Mr. Ruchelman and Ms. Erwin participated on the panel “Problems of U.S. Person Living in Europe,” which addressed banks that close accounts of U.S. persons, coming into compliance with tax return and F.B.A.R. reports, and planning for expatriation.

In conjuction with the conference, Mr. Ruchelman also spoke on the “Common Reporting Standard in the E.U.”

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ABA Tax Section: FIRPTA, Section 892 and REITS

Form W-8 Workshop

Wealth Planning in the "New Information Age"

Follow Up Work on B.E.P.S. Action 6: Preventing Treaty Abuse