The Internal Revenue Service recently issued proposed regulations under Section 956 of the Internal Revenue Code (IRC) that may allow foreign subsidiaries of U.S. multinational corporate borrowers to provide additional credit support to lenders without resulting in adverse U.S. federal income tax consequences. Although the proposed regulations may be relied upon by taxpayers for taxable … Continue Reading
Just in time for the holidays, the New Jersey Division of Taxation announced a tax amnesty program. Taking a “carrot and stick” approach, the Division of Taxation said that it would take amnesty applications from Nov. 15, 2018, through Jan. 15, 2019, for outstanding liabilities for taxes administered and collected by the New Jersey Division … Continue Reading
Greenberg Traurig’s private client/high net worth team has the experience to advise mega-lottery winners. Our attorneys have worked with individuals who have won some of the biggest lottery awards in the United States. Our approach to advising lottery winner clients is based on three basic principles: Family privacy, security, and freedom from publicity Tax and estate … Continue Reading
The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated by the IRS under Section 1274(d) of the Internal … Continue Reading
The Internal Revenue Service (IRS) publishes a monthly update to the applicable federal rates (AFRs) and 7520 rates. Planning professionals and their clients should take note of fluctuations in these rates and be mindful of planning opportunities that come with rate changes. The AFR is calculated by the IRS under Section 1274(d) of the Internal … Continue Reading
Whether to be closer to family member or a new job opportunity, individuals are increasingly relocating to another state. If reduction in the applicable state income tax is a motivating reason, avoiding dual-residency should be a primary objective. It is very common for owners of certain assets (closely-held businesses, highly-appreciated assets, and/or highly compensated executives … Continue Reading
A bill that would simplify state income tax compliance for employers when they send employees on temporary assignment to another state passed the House on Sept. 21. Many state government interests oppose the bill, so its future in the Senate is uncertain. Employers face a major state tax compliance headache when they send an employee on … Continue Reading
Portability refers to the ability of a surviving spouse, to make use of a deceased spouse’s unused estate tax exclusion amount (DSUE amount). Portability was intended to simplify estate planning for married couples by eliminating the need for a bypass trust. However, in order to preserve the DSUE amount the surviving spouse must comply with … Continue Reading
