During the pandemic many clients’ businesses have adversely impacted by lockdowns and many negotiations between borrowers and lenders have occurred or will occur in 2021. There will be many loan modifications, bankruptcies, and foreclosures. In
COVID-related legislation drove a lot of tax changes for 2020 and President-elect Joe Biden has proposed many tax changes for 2021. With tax laws already very complicated, we have some resolutions to get ahead in
Parag Patel last month co-presented a Tax Law Webcast to the District of Columbia (D.C.) Bar Association on “Post-Election Estate Planning and Audits: Tax Considerations for the Unexpected”. The program was hosted by D.C. Bar
As clients look for last-minute tax-saving strategies in 2020, one area that should be considered involves the changes to the charitable giving rules made by the 2020 CARES Act. The CARES Act established a ‘universal’ provision that allows
Any United States person with a “financial interest” in or “signature authority” over a foreign financial account, where the aggregate value of all foreign financial accounts exceeds $10,000 at any point during the year, must
One of the most likely changes in the tax law will be an increase in tax rates. For example, the Biden campaign has proposed increasing long-term capital gains and qualified dividends currently at 20% up
It appears more likely than not the United States is headed towards a split government next year. For purposes of tax planning next year, we can probably assume that control of Congress is divided between
The IRS revised its Delinquent International Information Return Submission Procedure (DIIRSP) last week. The DIIRSP provided an alternative 0% penalty voluntary disclosure process to taxpayers other than the Offshore Voluntary Disclosure Program or the Streamlined
The estate and gift tax exemption, which allows each U.S. person to pass a certain amount of assets free of the federal estate and gift tax, was doubled under the 2017 Tax Cuts and Jobs
With the upcoming election and potential tax law modifications based on the outcome, high net worth married couples should consider meeting with their advisors to determine what they can do to prepare for potential tax
After a misworded posting caused confusion about the 2020 deadline to file FBARs (i.e., FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)), Treasury’s Financial Crimes Enforcement Network (FinCEN) has extended the deadline
The IRS has recently begun sending “soft letters” (warning letters) to U.S. taxpayers owning foreign companies about IRC Section 965 transition tax compliance. In July 2020, The IRS Large Business & International (LB&I) division expanded
