The UK Supreme Court's decision in Rubin v Eurofinance, declaring that an order made in Chapter 11 bankruptcy proceedings in the US could not be enforced as a judgment of the English courts. The ruling could have significant repercussions in the British Virgin Islands and Cayman Islands. As was reported last week by The Lawyer…
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The Souteast Still The Tax Fraud Capital of the US
• Panama City Beach, Fla.: A tax preparer has been arrested on charges that he used copies of clients' tax returns to steal their identities. • Montgomery, Ala.: Two more tax preparers have joined those pleading guilty in a scheme involving more than $1 million. • Washington, D.C.: Preparer Enyinnaya Udo was sentenced to two…
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U.S. Engaging with More than 50 Jurisdictions to Curtail Offshore Tax Evasion
The U.S. Department of the Treasury today announced that it is engaged with more than 50 countries and jurisdictions around the world to improve international tax compliance and implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target…
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No PAL Exception for Real Estate Held in Trust! — CCA201244017
The main consequence of qualifying as a real estate operator under §469(c)(7) is that §469(c)(2), defining rental activities as per se passive, does not apply for the taxable year to the rental real estate activities of the taxpayer. The substance of §469(c)(7) is best considered in four stages: First, who qualifies as a real…
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