It’s Complicated
The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or avoidance of U.S. income tax.
Continue Reading Enough Already – Eliminate Downward Attribution and Accidental CFCs
Solace in the Mundane?
At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation, tighter credit, recession, crypto-nonsense, recreational cannabis, legalized gambling, men competing in women’s sports, a nation divided over all too many things, the Knicks down to the Heat 3 games to 2,[i] the prospect of Biden vs Trump II,[ii]. . . , the list goes on.[iii]
Continue Reading Indirectly Held Profits Interests and Rev. Proc. 93-27
Taxing the Rich
During the last couple of months, as we headed into what most folks – excluding transactional attorneys – call the “Holiday Season,”[i] tax authorities from around the globe have been calling for increased taxes on the rich, however one chooses to define this class of individuals.
The chief economist for the European Central Bank, relying on macroeconomic policy and concepts of “fairness,” advised governments to tax the rich to support society’s vulnerable groups.[ii]
In the U.K., His Majesty’s Revenue & Customs announced an initiative to pursue tax fraud by the wealthy and mid-size businesses. In fact, it has been reported that HMRC plans to go so far as to assign agents to personally monitor the tax affairs of certain individuals – an odd variation on the “buddy system.”
Continue Reading Pigs Get Fed, and Pay Their Taxes, But Hogs – That Remains to be Seen
I am delighted to launch TaxSlaw – where those hungry for tax knowledge come to chow down. Those who have been following me know that I have written about tax concerns for the closely-held business for more than a decade. I hope TaxSlaw– my opus, so to speak – will take that approach to