2025 Australian Federal Budget Summary On Tuesday, March...
In our 13th installment of the Family Office...
2024 Australian Federal Budget Summary On Tuesday 14th...
Subpart F Income: The Briefer
As mentioned in the previous blog, So You Own a CFC, What Now?, we introduced the fact that controlled foreign corporations must pay... Read more
What does ‘two-up’ have in common with selling Australian real estate while living in the US?
I am often asked how can a capital gain associated with your main residence that is tax-free in Australia be taxable in the... Read more
So You Own a CFC, What Now?
In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we analyze... Read more
Stage Five Clinger: How the TCJA Latches onto Unassuming Foreign Persons through Constructive Ownership
In our whitepaper, The Expansion of “United States” Taxpayers: How the TCJA Drags Unassuming Foreign Companies and Individuals under its Scope, we discuss... Read more
Part Three of the TCJA Attribution Rules: Down the Rabbit Hole
In our blog post titled “Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”, we introduced how U.S. Shareholders of a... Read more
Part Two of the TCJA Attribution Rules: The Expansion Upward
In our blog post titled “Owning” Shares that Aren’t Yours: The Code’s Confusing Definition of “Ownership”, we introduced how U.S. Shareholders may be... Read more