Domestic & International

Tax Attorney


  • The Internal Revenue Service today launched a new program that will enable many employers to resolve past worker classification issues and achieve certainty under the tax law by voluntarily reclassifying their workers. This new program will allow employers the opportunity to get into compliance by making a payment covering past payroll tax obligations rather than […]

  • President Obama has signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the “Act”).  The Act, preserves the Bush tax cuts through 2012, cuts the estate tax to 35 percent and allows a $5 million individual exemption, cuts Social Security payroll taxes, and renews the alternative minimum tax patch for two […]

  • New proposed legislation would add compliance costs and responsibilities for U.S. payors and affect non-U.S. recipients of U.S. source income.  The new legislation, called the Foreign Account Tax Compliance Act of 2009 (“FATCA” OR “FATCAT”), would apply to any outbound payment made on of after January 1, 2011.  FATCAT has the following key provisions: FATCAT […]

  • Effective November 6, 2009, the Worker, Homeownership, and Business Assistance Act of 2009 permits taxpayers to make an election carrying back net operating losses arising in 2008 or 2009 for up to 5 years.  Prior to the new legislation, net operating losses generally could only be carried back for up to 2 years.  The carryback […]

  • 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 […]

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