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In a previous article, I discussed the rules for the downstream attribution of corporate stocks under the IRC (Internal Revenue Code) §318. Today, I would like to discuss the §318 upstream corporate attribution rules. §318 Upstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. Under […]
This article continues a series of articles on the constructive ownership rules of the IRC (Internal Revenue Code) §318. Today, we will discuss corporate attribution rules, even more specifically the §318 downstream corporate attribution rules. §318 Downstream Corporate Attribution: Two Types of Attribution There are two types of §318 corporate attribution rules: downstream and upstream. […]
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 […]
For some years now, India has remained at the top of all countries that receive remittances in US dollars. A lot of these funds flow from Indian-Americans and Indians who reside in the United States. The problem is that a lot of them are not in compliance with respect to their US international tax obligations […]
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, […]