Tax
Twelve Angry Taxpayers: Why the Constitution Might Guarantee a Jury Trial for Accuracy and Fraud Penalties in Tax Cases After SEC v. Jarkesy
This article considers the current constitutional status of the Internal Revenue Code (I.R.C.) §6662 accuracy penalties and I.R.C. §6663 penalties...
Individual Retirement Accounts: What a Long, Strange Trip It’s Been
In the November/December 2019 issue of The Florida Bar Journal, I outlined individual retirement arrangement/account (IRA) basics and warned readers...
Federal Tax Lien Remedies
Federal Tax liens are rarely just “tax issues” and can impact clients in a multitude of ways across several practice...
Taxed by Design? Florida’s Tax on Interior Design Contracts and What To Do About It
Florida sales and use tax can be full of surprises. Generally, sales and use tax applies to the sale or...
Putting Carts Before Horses: Why the Taxpayer Failed in Connelly v. United States, and the Effect on Business Succession and Estate Tax Planning
On June 6, 2024, the Supreme Court unanimously ruled for the IRS in Connelly v. United States, 144 S. Ct....
FinCEN Fenced In? CTA Held Unconstitutional, but Filing To Continue
On March 1, 2024, the federal district court for the Northern District of Alabama issued a memorandum opinion, National Small...
Tax Considerations for Contingent Interest and Convertible Debt in Cross-Border Lending Transactions
The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal...
Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax
A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to...
The Cashless Real Estate Deal: Beware of Phantom Withholding on Foreign Partners’ Income
Down markets yield an uptick in insolvent real estate transactions, which may result in cancellation of indebtedness income (COD income)....
Foreign Grantor Trust Planning: A Flexible Planning Structure for U.S. Income Tax
Over the years, U.S. tax practitioners specializing in international taxation have established foreign grantor trusts (FGTs) to assist multi-jurisdictional families...
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