2025 Australian Federal Budget Summary On Tuesday, March...
In our 13th installment of the Family Office...
2024 Australian Federal Budget Summary On Tuesday 14th...
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
The “Controlled Foreign Corporation” Regime: What is a CFC Anyway?
While the U.S. tax system appears to be federal in nature, the U.S. uses the Internal Revenue Code to cast a wide web... Read more
Is a Nonresident Alien’s Sale of a Partnership Interest a U.S. Trade or Business?
Our previous post, The Code Fails to Define a “U.S. Trade or Business,” even though You’re Still on the Hook for Paying Taxes... Read more