2025 Australian Federal Budget Summary On Tuesday, March...
In our 13th installment of the Family Office...
2024 Australian Federal Budget Summary On Tuesday 14th...
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
Family Attribution Rules
What is Attribution? Attribution is an artificial concept used for tax purposes to prevent tax avoidance. This artificial concept treats a person/taxpayer as... Read more
“Owning” Shares that aren’t Yours: The Code’s Confusing Definition of “Ownership”
The Code employs various definitions of what constitutes “ownership” in various circumstances, and with regards to the classification of foreign companies as CFCs,... Read more