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Document(s) published by this organization: 15
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 | Testamentary Limited Power of Appointment May Not Prevent Transfer to Irrevocable Trust From Being Subject to Gift Tax Berger Singerman LLP;
Legal Alert/Article April 26, 2012, previously published on April 2012 On February 24, 2012, the IRS Office of Chief Counsel issued an internal legal memorandum No. 201208026 which appears to negate a common practice for avoiding gift tax on the transfer of assets to an irrevocable trust. This common practice entails giving the grantor of the trust a testamentary...
|  | New IRS Form 8938 - Statement of Specified Foreign Financial Assets Berger Singerman LLP;
Legal Alert/Article March 28, 2012, previously published on March 2012 Certain US individual taxpayers may be required to complete new IRS information Form 8938 (Statement of Specified Foreign Financial Assets) and attach it to their 2011 US Federal income tax returns to report their interests in certain “specified foreign financial assets.” It is...
|  | Revocation of QSUB Status of Chapter 11 Debtor Violates Automatic Stay Michael R. Harris, Nick Jovanovich, Daniel D. Mielnicki, Marian Pearlman Nease, Sheldon S. Polish, William M. Shaheen, Alfredo R. Tamayo; Berger Singerman LLP;
Legal Alert/Article February 24, 2012, previously published on February 2012 This Tax Alert discusses a recent Delaware Bankruptcy Court case, In Re: The Majestic Star Casino, LLC, 2012 WL 204088 (Bktcy Ct. DE 1/24/2012), involving a non-debtor S corporation (“Parent Corporation”) which revoked its S corporation status, thereby causing the automatic revocation...
|  | IRS Offshore Voluntary Disclosure Program Reopens Michael R. Harris, Nick Jovanovich, Daniel D. Mielnicki, Marian Pearlman Nease, Sheldon S. Polish, William M. Shaheen, Alfredo R. Tamayo; Berger Singerman LLP;
Legal Alert/Article January 25, 2012, previously published on January 2012 On January 9, 2012, the Internal Revenue Service (“IRS”) announced the reopening of the Offshore Voluntary Disclosure Program (“OVDP”) as a way for U.S. taxpayers with undisclosed foreign accounts, assets and income to become compliant with U.S. tax law. The OVDP follows the...
|  | “Honest Services” Fraud After Skilling Berger Singerman LLP;
Legal Alert/Article January 25, 2012, previously published on January 2012 On November 16, 2011, the United States Court of Appeals for the Second Circuit issued an opinion vacating the conviction of Joseph Bruno on charges of honest services fraud in violation of 18 U.S.C. § 1346. United States v. Bruno, 2011 WL 5555611 (2d Cir. 2011). The Bruno case, which may have...
|  | Liability of the Qualifying Agent for the General Contractor Jeffrey S. Wertman; Berger Singerman LLP;
Legal Alert/Article January 18, 2012, previously published on January 2012 Florida law imposes a requirement on a business organization engaged in general contracting to apply for a certificate of authority to conduct business through a “qualifying agent” or “qualifier.”
|  | Interest Charge-Domestic International Sales Corporations (“IC-DISC”) The Exporter’s Federal Tax Break Michael R. Harris, Nick Jovanovich, Daniel D. Mielnicki, Marian Pearlman Nease, Sheldon S. Polish, William M. Shaheen, Alfredo R. Tamayo; Berger Singerman LLP;
Legal Alert/Article January 9, 2012, previously published on January 2012 International trade has been and remains big business in Florida. The U.S. Census Bureau has estimated that Florida firms exported over $55 billion of products in 2010, and that Florida is the fourth largest exporting State in the U.S.
|  | Tax Provisions Scheduled to Expire in 2011 Michael R. Harris, Nick Jovanovich, Daniel D. Mielnicki, Marian Pearlman Nease, Sheldon S. Polish, William M. Shaheen, Alfredo R. Tamayo; Berger Singerman;
Legal Alert/Article December 26, 2011, previously published on December 2011 Last December, President Obama signed into law the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the “2010 Tax Relief Act”) which included certain temporary tax breaks for individuals and businesses, some of which are scheduled to expire at the end of...
|  | What to Do Now That the 2011 Offshore Voluntary Disclosure Initiative Has Ended Michael R. Harris, Nick Jovanovich, Daniel D. Mielnicki, Marian Pearlman Nease, Sheldon S. Polish, William M. Shaheen, Alfredo R. Tamayo; Berger Singerman;
Legal Alert/Article November 25, 2011, previously published on November 2011 The Voluntary Disclosure Program which existed prior to the implementation of the 2011 OVDI remains an option for U.S. taxpayers to become compliant with U.S. tax and reporting requirements. This program is a creation of IRS administrative policy that has and will continue to evolve as the IRS...
|  | Charitable Gifts - Appreciated Stock Michael R. Harris, Nick Jovanovich, Daniel D. Mielnicki, Marian Pearlman Nease, Sheldon S. Polish, William M. Shaheen, Alfredo R. Tamayo; Berger Singerman;
Legal Alert/Article November 1, 2011, previously published on October 2011 Now that we have entered the last quarter of 2011, it would be an appropriate time to start reviewing your tax situation for the year and plan accordingly. One of the basic tax planning techniques used by many individuals to help reduce their tax liability for the year is to make charitable...
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