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Tax

Bon Voyage to the Offshore Voluntary Disclosure Program

The end of a popular IRS program will have significant ripple effects for taxpayers.

On March 13, 2018, the Internal Revenue Service announced that it would begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and would close the program ...

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Hedge Funds | Private Equity

To Help Businesses Pursue Global Opportunities, Be Mindful of Local Culture and Characteristics

Timothy Speiss, partner-in-charge of Eisner’s personal wealth and Asia practices, discusses the challenges and opportunities in global business expansion.​

CCBJ: Describe your background and current practice for our readers.

Tim Speiss: I’ve been practicing in the tax and...

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Insurance Coverage & Recovery

Avrahami v. Commissioner: Good News or Bad News? It Depends

A reminder that a captive insurance arrangement cannot be reverse-engineered without a focus on providing insurance as it’s commonly understood.

On August 17, 2017, the U.S. Tax Court decided Avrahami v. Commissioner, a “Division Opinion” by Tax Court Judge Mark Holmes, and...

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