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 [...]
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 [...]
In Bound Transactions-Business Income
Inbound Transactions – Business Income “Business Income” is income that [...]
Other In Bound Rules
I will elaborate on the following four areas: Capital Gains [...]
Decision Tree
Decision Tree 1: Inbound TransactionsAnalysis for Foreign Persons or Foreign [...]
Branch Profits and FIRPTA
Branch Profits Tax and FIRPTA Where we are to date: [...]