The Florida Bar

Florida Bar Journal

The Florida Bar Journal

Tax

Tax Considerations for Contingent Interest and Convertible Debt in Cross-Border Lending Transactions

Tax
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

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

Featured Article
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

Tax
Over the years, U.S. tax practitioners specializing in international taxation have established foreign grantor trusts (FGTs) to assist multi-jurisdictional families...

Corporate Transparency Act Reporting Rules Finalized, But Will Access Issues Cause Delay?

Tax
As of this writing (June 15, 2023), the Corporate Transparency Act (CTA)[1] is scheduled to take effect on January 1,...

Designing Trust Systems for Florida Residents: Planning Strategies, Things You Should Know, and Traps for the Unwary

Featured Article
Revocable and irrevocable trusts are commonly used as the primary platforms for estate and financial planning for individuals, married couples,...

Internal Revenue Code §1202 and You: Analyzing Exclusion of Gain on Sales of Small Business Stock

Tax
Section 1202 of the Internal Revenue Code provides a way for taxpayers to exclude much, if not all, of the...

Innocent Spouse Relief from Joint and Several Federal Tax Liability: Updates, Hurdles, and Considerations

Tax
Married couples can choose to file either joint tax returns or separate tax returns for federal income tax purposes.[1] In...

QDRO Math: Advice to Plan Administrators in Florida

Tax
Protecting retirement fund assets for public policy purposes has been deeply rooted in our nation’s history for as long as...

Reflections on a Vetoed Bill

Tax
On June 24, Gov. Ron DeSantis vetoed Senate Bill 1382, preventing the Department of Revenue from moving forward with sweeping...