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This article continues a series of articles concerning US tax classification of unusual foreign entities; our focus is on the determination whether these entities should be classified as foreign business entities or foreign trusts. Today’s topic is the Hindu Undivided Family, the preferred legal entity for managing family estates for a large number of wealthy […]
In a previous article, I discussed the IRC (Internal Revenue Code) §318 general rule on the re-attribution of corporate stock; in that context, I mentioned that there are certain restrictions on §318 re-attribution. Today, I would like to discuss one of such restrictions – §318 double-inclusion prohibition. §318 Double-Inclusion Prohibition: General Re-Attribution Rule Before we […]
On February 28, 2020, the Internal Revenue Service (“IRS”) announced that the 2020 Second Quarter IRS underpayment and overpayment interest rates (“2020 2Q IRS Interest Rates”) will not change from the first quarter of 2020. This means that, the 2020 2Q IRS interest rates will be as follows: Under the Internal Revenue Code, these interest […]
In an earlier article, I discussed the advantages of the Streamlined Domestic Offshore Procedures (“SDOP”) in the year 2020. Among the advantages, I mentioned the SDOP Miscellaneous Offshore Penalty (hereinafter “SDOP Penalty”), but never explained this concept. The focus of this article is on the 2020 SDOP Penalty and how one generally should calculate it. […]
This article continues a series of articles on the Internal Revenue Code (“IRC”) §318 constructive ownership rules. Today, I would like to focus on the §318 re-attribution rule. In this article, I will explain the general §318 re-attribution rule and mention the exceptions. I will discuss the exceptions in more detail in future articles. §318 […]