Asset Protection Planning with Limited Liability Companies
The basic objective of asset protection engagements is to transfer assets to reduce or eliminate any exposure to liabilities in conjunction with the client’s estate plan or other financial concerns
Published on October 01, 2008
Using Retirement Benefits to Achieve Charitable Objectives
This item explores several options for taxpayers to use retirement plan benefits to fund charitable objectives
Published on September 01, 2011
Individuals Use of Offshore Holding Companies (Part II)
...more significant investments in foreign businesses, including situations in which the use of an offshore holding company may be consistent with bona fide U.S. federal income tax planning objectives
Published on September 01, 2007
Family Investment Partnerships All the Perks
Family investment partnerships are frequently used to manage and control multigenerational family wealth and may result in significant economic and tax benefits.
Published on March 01, 2012
National Taxpayer Advocate Warns of IRS Mission Expansion
In the introduction to her recent report to Congress, IRS National Taxpayer Advocate (NTA) Nina Olson warns that recent expansion of the IRS mission is straining some of its core capabilities.
Published on October 01, 2010
Compilation and Review Engagements
A description of publications available on compilation and review engagements.
Published on March 13, 2015
Preparing Canadian Structures for 2010
Effective January 1, 2010, Canada will look through tax-transparent U.S. LLCs and determine treaty eligibility at the member level.
Published on September 01, 2009
District Court Allows R&D Credit for Prototype Costs
In a recent case, the court held that the taxpayer is, in certain situations, entitled to the Sec. 41 research credit for qualified research expenditures (QREs) for activities relating to the design, development, and construction of new types/classes of ships.
Published on June 01, 2010
OECDs Draft Proposal on Treaty Shopping, Treaty Abuse Situations
The OECD recently issued a report that includes proposed changes to the Model Tax Convention, which are intended to prevent treaty abuse, and commentary on the changes.
Published on March 01, 2015
IRS Releases Prop. Regs. on Series LLCs
This item reviews proposed regulations the IRS released in September on the tax treatment of series limited liability companies and foreign cell companies, proposing to treat the individual series or cells as separate entities for tax purposes.
Published on November 01, 2010