McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more
12/4/2023
/ Charitable Donations ,
Corporate Transparency Act ,
Cryptocurrency ,
Employees ,
Employer Liability Issues ,
Estate Planning ,
Estate Tax ,
Family Offices ,
FinCEN ,
Gifts ,
Green Book ,
High Net-Worth ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Reporting Requirements ,
Tax Deductions ,
Trusts ,
U.S. Treasury ,
Wealth Management ,
Wills
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011....more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon...more
The IRS announced on March 13, 2018, that it will begin to ramp down the current OVDP and urged taxpayers with undisclosed foreign assets to apply for the program before it closes on September 28, 2018....more
The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit to enroll in the streamlined filing compliance procedures (SFCP). SFCP is a program offered by...more