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Noncompensatory Option Regs are Finalized: Where do Mezz Funds go from Here?

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February 4, 2013
Noncompensatory Option Regs are Finalized: Where do Mezz Funds go from Here?

The noncompensatory option regulations have been subject to much debate and discussion, including by me on this blog. After many, many years in circulation, the famous or infamous proposed regulations were just finalized. Considering that the final regs came out just a few hours ago, I have not had the time to fully review...
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NEWT Act Reintroduced

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February 1, 2013
NEWT Act Reintroduced

For those who keep up with the net investment income tax (NIIT) and the S-corporation planning touted by many practitioners as a solution for minimizing both NIIT and employment tax, here is a fresh news to keep in mind.  The Narrowing Exceptions for Withholding Taxes Act of 2013, or so called NEWT Act (purportedly...
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A Few Additional Thoughts on the Net Investment Income Tax

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January 25, 2013
A Few Additional Thoughts on the Net Investment Income Tax

I spent some more time with the NIIT proposed regulations and I also reviewed quite a few alerts by reputable firms and articles by renowned tax practitioners.  There are two buzz words that popped up in my NIIT adventures: “S-corporation” and “grouping activities.”  It seems like practitioners are focused on these two elements in...
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Net Investment Tax Proposed Regs are Out!

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December 11, 2012
Net Investment Tax Proposed Regs are Out!

I am a bit late to the party since the regulations actually came out a few days ago, but nonetheless, I wanted to share my first impressions. These have been long awaited by the community and they do not disappoint. One hundred and fifty nine pages, including the preamble, but I am not going...
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Moving from FS-2011-13 to Streamlined FBAR Compliance

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September 4, 2012
Moving from FS-2011-13 to Streamlined FBAR Compliance

So the IRS has moved one step closer to providing US taxpayers living abroad with somewhat of an easier and clearer compliance procedure for filing delinquent FBARs.  The possible recipient of this boon is a client with a story that goes like this. I lived in the US, I moved out, I paid taxes...
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