Domestic & International

Tax Attorney


  • U.S. informational reporting requirements for U.S. persons who own shares of a foreign mutual fund  or  other “commingled fund” are remain unclear.  A U.S. person who invests in a foreign mutual fund through a foreign brokerage account is certainly required to report such ownership on their Form TD 90-22.1 (“FBAR”).  Reporting requirements for U.S.  persons […]

  • Protocol to U.S.-New Zealand income tax treaty sent to U.S. Senate.  The proposed protocol includes updates to rules on limitation of benefits, nondiscrimination, & information exchange.

  • President Obama clarified his proposed international tax reforms.  The President’s proposals would become effective in 2011 and raise a projected $210 million for the Federal government.  Highlights include: reformation of the so-called “check-the-box rules” as they apply to foreign entities reformation of the foreign tax credit so foreign income and the foreign tax credit are […]

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