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Deconstructing Hedge Fund Schedule K-1s for Individuals
Federal Taxation
Hedge fund K-1s can be voluminous and difficult when determining how to handle the tax treatment of the income and deductions…
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Federal Investigators Increase Scrutiny of Offshore Bank Accounts
Federal Taxation
Federal watchdogs are demonstrating their renewed focus on the illegal use of offshore bank accounts, as the Department of…
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To Have and to Hold But to Not Be Held Accountable
Federal Taxation
New Year’s Eve is not just a time for fireworks and celebrations—it is also the moment when the IRS determines whether or…
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A Brief Update on Filing Requirements for U.S. Citizens Living Abroad and Resident Aliens in the United States
Federal Taxation
Who has to file Form 1040NR? instructions Information Reporting About Employer Offer of Coverage If someone in a specified…
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Proposed Regulations Under IRC Section 2704
Federal Taxation
On Aug. 2, 2016, the U.S. Department of the Treasury and the IRS issued proposed regulations under IRC Section 2704 (the…
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Fundamental Tax Reform Is Mostly Dead—but Not Quite
Federal Taxation
In the classic children’s movie The Princess Bride, Billy Crystal plays a miracle-performing medicine man. When the hero of…
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New Seller Due Diligence Responsibilities After the Midco Cases?
Federal Taxation
In the post-General Utilities world, shareholders have looked to dispose of their interest in C Corporations with appreciated…
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Is It Debt or Equity? A Survey of the Proposed Section 385 Regulations
Federal Taxation
The fundamental question investors address when capitalizing a business is how it should be funded—with debt, equity, or a…
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Foreign Trust Reporting: Substance Over Forms? I Think Not
Federal Taxation
In a world dominated by data, the IRS’s role in data collection continues to expand. No longer is the agency’s sole focus…
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