Blogs

Tax Controversy & Financial Crimes Report

The increasingly complex area of tax law in the U.S. can cause a variety of legal setbacks for any business. The more notable the tax controversy, the more roadblocks that can be created between a company and its success. Our Tax Controversy & Financial Crimes Report blog addresses the latest developments in all aspects of tax controversy matters and incorporates coverage of efforts to combat financial crimes, particularly money laundering.

View Blog

Current Developments in Business & International Taxation

Published by Jerry August, this blog provides news and analysis of the latest trends in state, federal and international business taxation. You’ll find summaries of major tax legislation such as the Tax Cuts and Jobs Act of 2017, updates on significant changes in state, federal and international tax law and in-depth analysis of important court rulings that affect businesses’ tax exposure, and subsequently their bottom lines.

View Blog

Recent Blog Posts

  • Expatriation From the United States of High Net Worth Individuals and Families to Avoid High Levels of Income and Wealth Tax: Meet The US Inheritance Tax on Gifts From Covered Expatriates By: Jerald David August Chair, International Taxation and Wealth Planning Group This is the fourth and last segment to the set of posts that summarizes the expatriation rules contained in the Internal Revenue Code. This last segment addresses exceptions to the mark-to-market rules under Section 877A and moves onto to address the somewhat overlooked succession tax under Section 2801. Exceptions to the Mark-to-Market Tax Under Section 877A The mark-to-market tax applies to most types of property interests held by the individual on the... More
  • Expatriation From the United States of High Net Worth Individuals and Families to Avoid High Levels of Income and Wealth Tax: Meet the Mark-to-Market Regime By: Jerald David August Chair, International Taxation and Wealth Planning Group   Set of Expatriation Blog Posts This is the third in a series of blog posts on the US income and wealth tax implications of expatriation. This post sets forth the U.S. approach to the expatriation of a U.S. citizen and long-tern resident prior to the effective date of the Heroes Act of 2008 which applied to expatriations occurring after June 16, 2008.... Continue Reading... More
  • Expatriation From the United States of High Net Worth Individuals and Families to Avoid High Levels of Income and Wealth Tax By: Jerald David August Chair, International Taxation and Wealth Planning Group Set of Expatriation Blog Posts This is the second in a series of blog posts on the US income and wealth tax implications of expatriation. This post sets forth the U.S. approach to the expatriation of a U.S. citizen and long-tern resident prior to the effective date of the Heroes Act of 2008 which applied to expatriations occurring after June 16, 2008.... Continue Reading... More
  • With Left-leaning Politicians Running for President Seeking to Impose An Annual Excise Tax on Wealth Will Wealthy US Citizens and Long-Term Residents Expatriate? By: Jerald David August Chair, International Taxation and Wealth Planning Group   Introduction of Set of Expatriation Blog Posts This is the first in a series of blog posts on the US income and wealth tax implications of expatriation. This post sets forth an introduction into the minefield of tax and non-tax considerations for an individual to consider, with the advice of US and foreign legal and tax counsel, on the merits and drawbacks of expatriation.... Continue Reading... More
  • Fox Rothschild Attorneys to Present at PACDL’s Annual White Collar Conference Fox Rothschild attorneys Ryan T. Becker and Matthew D. Lee will be speaking next week at the annual White Collar Practice conference sponsored by the Pennsylvania Association of Criminal Defense Lawyers.  The conference will take place on November 21-22, 2019, in Philadelphia. Ryan will be moderating a panel entitled “Internal Investigations:  Protecting Your Client While Placating the Government.” Matt will be speaking on a panel entitled “What You Really Need to Know if You Are Taking on a Criminal Tax Case.” Details about the... More
  • IRS Steps Up the Pressure on Abusive Syndicated Conservation Easements The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area.  According to the announcement, coordinated audits are being conducted throughout various examination divisions of the IRS.  At the same time, the IRS Criminal Investigation division has criminal investigations underway in this area. These audits and investigations cover billions of dollars of potentially inflated deductions as well as hundreds of partnerships and thousands of investors. Syndicated conservation easements are included on the... More
  • Matthew D. Lee Updates Foreign Account Tax Compliance Act Answer Book for 2019 Fox Rothschild LLP Partner Matthew D. Lee authored an updated version of the Foreign Account Tax Compliance Act Answer Book, which was originally published by Practising Law Institute in 2015. This new edition addresses recent changes to FATCA regulations relating to compliance and verification procedures for a variety of entities, including sponsoring entities of foreign financial institutions; non-financial foreign entities; trustees of trustee-documented trusts; registered deemed-compliant FFIs; and financial institutions that implement consolidated compliance programs. The update examines revisions to the responsible officer... More
  • Matthew D. Lee Updates Foreign Account Tax Compliance Act Answer Book for 2019 Originally published by Practising Law Institute in 2015, this new edition addresses recent changes to FATCA regulations relating to compliance and verification procedures for a variety of entities, including sponsoring entities of foreign financial institutions; non-financial foreign entities; trustees of trustee-documented trusts; registered deemed-compliant FFIs; and financial institutions that implement consolidated compliance programs. The update examines revisions to the responsible officer compliance certification process and the FATCA registration and renewal process. It also describes recent offshore tax evasion criminal and civil... More
  • FinCEN Unveils New Global Investigations Division to Target Foreign Money Laundering Threats The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced today that it has launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies to combat illicit finance threats and related crimes, both domestically and internationally. Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s Criminal Division, will lead GID. GID will build upon FinCEN’s existing authorities under the Bank Secrecy Act, including Section 311 of the USA PATRIOT Act, to investigate and... More
  • Service Issues Proposed Regulations On Withholding and Reporting For Certain Partnership Dispositions By Non-US Persons By: Jerald David August, Chair, Fox Rothschild LLP International Taxation and Wealth Planning Group The Internal Revenue Service recently issued proposed regulations, REG-10476-18, 2019-27 IRB 63, with respect to withholding and information reporting for certain dispositions of partnership interests by non-US persons who are partners in a partnership that is engaged in the conduct of a US trade or business. Under the Tax Cuts and Jobs Act, P.L. 115-97, section 864(c)(8) of the Code was amended to reverse the holding of... More