Tax
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Tax
The Exit Tax: Three Years After The Introduction Of Section 877A.
It has been more than three years since the enactment of Sec. 877A, which introduced a mark-to-market tax on U.S. persons expatriating on or after June 16, 2008. Official records indicate that, although still relatively small, there is an increasing number of U.S. persons who have renounced, or...
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UK Residence: Greater Certainty In The Works
An individual’s UK tax residence status has a significant bearing on the amount of income and gains that is taxable in the UK. Somewhat surprising then is the fact that the United Kingdom does not have a clear definition of UK tax residence. The current definition rests primarily on court...
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Treasury Issues Proposed Regulations Under Section 382 That Would Ease Compliance Requirements For Tracking Small Shareholder Ownership
Introduction On November 23, 2011, the Internal Revenue Service (the "IRS") issued new Proposed Regulations under Section 3821 that, if adopted and finalized, would limit the application of the Section 382 segregation rules (discussed in detail below) to public groups in...
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