Entries by Manager

2020 IRS Standard Mileage Rates | IRS Tax Lawyer & Attorney

Beginning January 1, 2020, the IRS changed the optional standard mileage for the calculation of deductible costs of operating an automobile (sedans, vans, pickups and panel trucks) for business, charitable, medical or moving purposes. Let’s discuss in more detail these new 2020 IRS Standard Mileage Rates. 2020 IRS Standard Mileage Rates for Business Usage For […]

§318 Employee Trust Attribution | Foreign Trust US Tax Law Firm

In a previous article, I explained special §318 rules concerning grantor trusts as an exception to the general §318 trust attribution rules. Today, I will discuss the special §318 employee trust attribution rules as another exception to the general §318 trust attribution rules. §318 Employee Trust Attribution: Focus on Tax-Exempt Employee Trusts First of all, […]

§318 Grantor Trust Attribution | Foreign Trust Tax Lawyer & Attorney

In previous articles, I discussed the §318 downstream and upstream attribution rules; in that context, I also mentioned that there were special rules concerning grantor trusts and tax-exempt employee trusts. This article will cover the special §318 grantor trust attribution rules. §318 Grantor Trust Attribution: Definition of Grantor Trust A grantor trust is any trust […]

§318 Upstream Trust Attribution | US Foreign Trust Tax Lawyer & Attorney

In a previous article, I discussed the Internal Revenue Code (“IRC”) §318 downstream trust attribution rules. Today, I would like to focus on the §318 upstream trust attribution rules. §318 Upstream Trust Attribution: Downstream vs. Upstream There are two types of §318 trust attribution: downstream and upstream. In a previous article, I already covered the […]