Entries by Manager

Expatriation Tax: “Covered Expatriates” under Notice 2009-85

As an international tax attorney who constantly deals with expatriates, I am often contacted by individuals who are thinking about renouncing their U.S. citizenship. If you are consideration going down this path, you should understand the very serious legal and tax implications of this strategy. On the tax side, you should be especially aware of […]

IRS Issues a Proposed Regulation Regarding Employer-Sponsored Healthcare Plans

The IRS recently issued a proposed rule entitled, “Minimum Value of Eligible Employer-Sponsored Plans and Other Rules Regarding the Health Insurance Premium Tax Credit” (see, 26 CFR Part 1) regarding the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, and related rules and laws (generally, “PPACA”). In […]

Forms 3520 and 3520-A and Increased Use of Foreign Trusts

The Internal Revenue Service recently released its Statistics of Income Studies (SOI) reports concerning data for 2010 foreign trusts that have U.S. persons as grantors, transferors, or beneficiaries. The data shows that, despite the various compliance costs associated with reporting requirements, use of foreign trusts by U.S. taxpayers continues to increase. This article will briefly […]