Taxation of Gifts From Foreign Persons

Generally, nonresident aliens (“NRAs”) are only subject to tax on income from U.S. sources and income received in connection with the conduct of a trade or business within the U.S. However, in certain circumstances, an NRA may also be subject to wealth transfer tax (i.e., estate and gift tax). This memorandum presents an overview of … 더 읽기

The Art Collector

Tourists don’t line up outside Richard Greene’s law firm. But if art lovers knew about the treasure trove inside, they might beg for a peek at the paintings, lithographs and sculptures lining the firm’s walls. Greene, a name partner at Greene Radovsky Maloney & Share, and his wife Lorrie, have been collecting art for the … 더 읽기

Top Attorneys

Se você precisa de um advogado para ajudá-lo com uma transação de imóveis comerciais na Área da Baía, você tem muitas opções excelentes. Esse é o consenso de corretores, executivos de investimentos imobiliários e os próprios profissionais. Na nossa última parcela de Top Attorneys, The Recorder está tentando identificar o creme da cultura. Nós entrevistámos 30 corretores … 더 읽기

General Analysis of American Recovery and Reinvestment Act

The Act, signed into law by President Obama on February 17, 2009 includes significant changes to various provisions of the Internal Revenue Code of 1986, as amended (the “Code”). This memorandum summarizes these changes, highlighting those provisions of relevance to investors and businesses. Except as otherwise noted, the tax provisions of the Act are retroactive … 더 읽기

Tax Court rejects IRS’s position that member interests in an LLC are limited partnership interests for passive activity rule purposes under IRC §469.

DOWNLOAD ARTICLE Tax partner Ed Kaplan successfully represented the taxpayer against IRS proposed tax assessments in excess of $2,000,000 in Newell v. Commissioner, TC Memo 2010‑23. In adopting Ed’s arguments, the Tax Court rejected the Service’s long‑standing position that member interests in LLCs are to be treated solely as limited partnership interests for purposes of the passive … 더 읽기

Taxation of Gifts From Foreign Persons

DOWNLOAD ARTICLE Generally, nonresident aliens (“NRAs”) are only subject to tax on income from U.S. sources and income received in connection with the conduct of a trade or business within the U.S. However, in certain circumstances, an NRA may also be subject to wealth transfer tax (i.e., estate and gift tax). This memorandum presents an … 더 읽기

Exploring Different Casino Games

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