Debt Cancellation Tax Consequences
Financially distressed borrowers may have some or all of their [...]
Partnership Special Allocations
One of the advantages of operating a business as a [...]
Residency
ResidencyTwo Different Tax Regimes: US persons and Non-US personsU.S. persons [...]
Subpart F Income
Subpart F Income When a US person owns shares in [...]
Expatriates
Expatriates & SourcingExpatriatesThe tax code provides an exemption for expatriates [...]
Transfer Pricing and Transfer of Property Outside the US
Transfer Pricing and Transfer of Property Outside the US Transfer [...]
Corporations and Branches
I will elaborate on the following areas: Difference between a [...]
Like Kind Exchanges of Real Property
Like Kind Exchanges of Real Property
Sourcing Rules Examples
Source Rules for Income I/ Interest: Rule: Residence of Payor [...]
Inbound Transactions – Non-Business Income
Inbound Transactions – Non-Business Income Now that we’ve distinguished between [...]