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Voluntary Disclosure
OFFSHORE ACCOUNTS Increased information exchange Taxpayers are seeing many countries, especially the US with its Foreign Account Tax Compliance Act (FATCA) and the OECD Countries…Streamlined Disclosure
Streamlined Filing Compliance On June 18, 2014, the IRS announced changes to the existing Streamlined Filing Compliance Procedure, which had been in effect since September…KNOWING YOUR OPTIONS
KNOWING YOUR OPTIONS AND AVOIDING TRAPS FOR THE UNWARY Increased information exchange Taxpayers are seeing many countries, especially the US with its Foreign Account Tax…IRS ENFORCEMENT ACTIONS
INTERNAL REVENUE SERVICE ENFORCEMENT ACTIONS On October 15, 2015, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix…
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The purpose of this section entitled nonresidents: U.S. portfolio investments is to explain the basic principles of the source of income rules and the statutory basis for taxation of foreign taxpayer’s portfolio and passive income.
landmark litigation
STATES RIGHT TO TAX CRUISE TO NOWHERE
Various taxes owed by cruise operator with respect to gambling equipment and gambling concessions on so-called cruises to nowhere must be prorated (New Sea Escape Cruises Ltd. v. Florida Department of Revenue, Fla. Dist. Ct. App., No. 4D00-3873, 6/26/02).
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ASSOCIATION OF INTERNATIONAL TAX COUNSEL (AITC)
AITC is an association of independent professional firms composed of lawyers and accountants specialized in tax. Globally our members can be found in over 60 jurisdictions.