Tax
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...
Corporate Transparency Act Reporting Rules Finalized, But Will Access Issues Cause Delay?
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
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
Section 1202 of the Internal Revenue Code provides a way for taxpayers to exclude much, if not all, of the...
