The State Bar of California Taxation Section Annual Meeting of the California Tax Bar & California Tax Policy Conference
|
|
- Matthew Phillips
- 8 years ago
- Views:
Transcription
1 The State Bar of California Taxation Section 2012 Annual Meeting of the California Tax Bar & California Tax Policy Conference Session 4 Keeping Your Clients Out of Trouble FATCA Compliance Thursday, November 1, :40 AM 12:40 PM Points of view or opinions expressed in these pages are those of the speaker(s) and/or author(s). They have not been adopted or endorsed by the State Bar of California Board of Trustees and do not constitute the official position or policy of the State Bar of California. Nothing contained herein is intended to address any specific legal inquiry, nor is it a substitute for independent legal research to original sources or obtaining separate legal advice regarding specific legal situations State Bar of California All Rights Reserved
2 NO WRITTEN PROGRAM MATERIALS AVAILABLE AT PRESS TIME FOR PROGRAM 4 Keeping Your Clients Out of Trouble FATCA Compliance
3 Patrick W. Martin, Partner Practice Areas Tax International Law Private Client Admissions California Washington, D.C. Foreign Languages Spanish Professional Summary Direct Phone Direct Fax Mr. Martin is the leader of the firm's tax team. His practice emphasizes international tax planning and related international law matters. He represents foreign individuals, multi-national families, companies, international athletes, entertainers and entertainment groups in such areas as developing worldwide investment and financing structures, international tax treaty planning strategies and planning worldwide income, estate and inheritance taxes. He helps resolve and plan for international tax controversies and develops international wealth preservation structures to compliment the client s international investments and business transactions. In November, 2010 the Taxation Section of the California State Bar honored Mr. Martin with the prestigious V. Judson Klein Award for excellence in the practice of tax law. Representative Matters Represents various multi-national families in developing worldwide income, estate and inheritance tax and international wealth preservation structures including advising and defending audits by tax authorities. Advise U.S. and international investment funds regarding tax preferred structures for joint U.S.-Latin American land investment, private equity investment, cross border financing and repatriation of real estate profits. Advise foreign financial institutions (non-u.s.), foreign entities and their advisors and employees regarding the application, strategic decisions and implementation of the federal tax law, Foreign Account Tax Compliance Act. Represents international entertainers (including various Grammy Award winners) regarding tax planning considerations of their worldwide publishing, promotion, concerts, tax-exempt foundations, sales, and related activities. Represents various foreign families and individuals regarding pre-immigration and pre-expatriation planning to avoid and/or limit U.S. income, estate and gift tax consequences prior to: (a) immigrating into and taking up tax residency or domicile in the U.S., or (b) expatriating from the U.S. Represents several international income and estate tax audits before the IRS, including representation before the U.S. Tax Court. Assist numerous U.S. developers (joint ventures, land and construction development) with Mexican and Latin America (e.g., Costa Rica and Guatemala) real estate acquisitions and development; structuring global operations, financing, equity investment, repatriation of funds and tax treaty benefits. Represents various Mexican, Latin American, Asian, South Pacific and European manufacturing, technology and
4 agricultural companies with U.S. and worldwide joint venture, distribution and sales companies. Assist multiple Latin American real estate clients regarding private equity investment, financed sales and joint ventures with U.S. and Latin American individual and institutional investors. Assist various multi-million dollar Mexican real estate land owners with U.S. joint venture real estate developments. Education, Distinctions & Community Involvement Mr. Martin received his law degree from the University of San Diego School of Law in 1992 where he was a Thomas More scholar, and also studied international law (Régimen Jurídico de Los Negocios Internacionales en México) at the celebrated Mexican law school, La Escuela Libre de Derecho in Mexico City. He was a summer associate with the IRS District Counsel (Treasury Dept.). Mr. Martin is the past chair of the International committee, Taxation Section of the State Bar of California. He is a former chairman and current member of the San Diego County Bar Taxation Section, a member of the International Law Section of the State Bar of California, a past member of the Executive Committee of the Taxation Section of the State Bar of California, and a member of the American Bar Association. He is also licensed to practice in Washington, D.C., and is a member of the International Fiscal Association and the U.S. Tax Court. Mr. Martin is a member of the Advisory Board of Fondo Para La Paz and the Alumni Board of the University of San Diego School of Law. Mr. Martin is AV rated attorney by Martindale-Hubbell and was selected for inclusion from 2007 to 2012 in San Diego Super Lawyers lists in the Tax category. In 2010 the Taxation Section of the California State Bar honored Mr. Martin with the V. Judson Klein Award, for excellence in the practice of tax law. Mr. Martin has twice been selected by Citywealth Magazine to its North American Leaders List for lawyers who represent clients regarding wealth management, tax, estate, trust or philanthropy advice. He was most recently selected in 2010 along with 52 other attorneys throughout North America. News, Publications and Events Mr. Martin is frequently asked to speak at international tax and law conferences. He has also written extensively on matters of international tax law and a list of published articles can be provided upon request. Recent News Coverage 29 Procopio Attorneys Named San Diego Super Lawyers, Legal Netlink Alliance, June 1, Procopio Attorneys Named San Diego Super Lawyers, Procopio Press Release, June 1, San Diego Super Lawyers, Super Lawyers, San Diego Viswanathan, Usha. "Foreign Taxes," SmartBusiness San Diego, December Recent Articles/Publications Co-author. "Foreign Bank Account Reports Regulations Extend Rules to Many Unaware Persons," November "IRS Provides more Sensible Offer in its Increased Enforcement of Off-Shore Accounts and Assets of U.S. Taxpayers Residing Overseas," July Co-author. U.S. Tax Treaties and Section 6114: Why a Taxpayer's Failure to Take a Treaty Position Does Not Deny Treaty Benefits, CCH International Tax Journal, May-June "Limited Window of Opportunity to Avoid Tax Penalties ('Get Home Free Ticket')," February Co-author. "Overview of U.S. Interest Income, Exempt from U.S. Income Taxation for the Foreign Investor ( Portfolio
5 Interest )," February "Fiscalización de Contribuyentes de los E.U. Respecto de Cuentas Bancarias y Propiedades en el Extranjero - El IRS Extiende Oferta Especial a Aquellos Contribuyentes de los E.U. con Ingresos No Declarados en el Extranjero," Febrero "Foreign Individuals and the U.S. Estate Tax (similar to an Inheritance Tax)," January "FATCA se Estrella en la 'dimensión desconocida' (Residentes Legales Permanentes Residiendo en el extranjero)," Noviembre "FATCA of the HIRE Act Crashes Head on into the 'Twilight Zone'," CCH International Tax Journal, November Proposed Guidance on FBARs & Foreign Persons," State Bar of California Taxation Section International Tax Committee, September Co-author with Enrique Hernandez-Pulido. "What Happens in Mexico...is Taxed in the U.S.! How the New FATCA Provisions Affect Mexican Residential Trusts," March Co-author with Abel Mejia Cosenza. Comparative Overview of U.S. and Mexican Federal Employment Taxes, CCH International Tax Journal, November-December "Los Extranjeros y el Impuesto Sobre los Bienes de la Sucesión de los Estados Unidos (Similar al 'Inheritance Tax'," Abril "Forms of Doing Business in Mexico Compared to the U.S." October "I grandi miti fiscali sugli investimenti di stranieri in immobili statunitensi," June U.S. Taxation of Trusts - Mexico/U.S. Overview, California Tax Lawyer, Spring "Foreign Persons with Certain Visas and Their California Employers Beware: Non-Conformity of Federal and California Employment Tax Rules," California Tax Lawyer, Summer/Fall Co-author with Jon P. Schimmer. "Coming to America: The Throwback Tax s Ugly Head The Non-resident Alien Cum Resident as Beneficiary of Accumulated Income," CCH International Tax Journal, Summer Co-author with Jon P. Schimmer. "The Great Myth in Pre-Immigration Tax Planning Why Section 679(a)(4) Does Not Apply to Subtitle B (U.S. Estate, Gift and Generation Skipping Transfer Taxes)," California Tax Lawyer, Winter Co-author with Jon P. Schimmer. "Foreign Persons with Certain Visas and Their California Employers Beware: Non- Conformity of Federal and California Employment Tax Rules," July 1, FAQs - Investing in Mexican Real Estate, June 5, Cómo se dice FIRPTA" en Español? Un análisis Comparativo Fiscal Internacional Para Inversionistas Extranjeros de Bienes Raíces Americanos y Mexicanos, June Co-author with Enrique Hernandez-Pulido. How Do You Say "FIRPTA" In Spanish? A Comparative International Tax Analysis For Foreign Investors Of U.S. & Mexican Real Estate, June Oops - The Accidental Inversion: The Scope of Section To Certain In-Bound International Transactions Not Intended by Congress to be a Corporate Inversion, State Bar of California Taxation Section International Committee, April 25, Co-author with Enrique Hernandez-Pulido. "Mexico's New Proposal for International Tax Anti-Deferral Rules," October 1, 2004 "Why Section 2104 Must Address When Partnership Interests Owned by Foreign Investors are (and are not) Subject to
6 United States Estate Tax," State Bar of California Taxation Section International Committee, May "Why Regulation (b)-1(b) and the Definition of Lawful Permanent Resident Must Address Non-U.S. Citizens Who Have Left and Permanently Reside Outside the United States," State Bar of California Taxation Section International Committee, April "U.S. Tax Implications of Foreign Investment in U.S. Real Estate," October 9, Overview of Trademark Registration Process in Central and South America, August 26, "IRS Reporting Requirements for Foreign Partnerships," August 26, "The One-Edge Sword: The High Risks of Commercial Transactions in Mexico," August 26, "Legal and Practical Issues Involved with Maquiladora Financing," Law and Business Review of the Americas, Winter/Spring "Comparative Analysis of U.S. vs. Mexican Commercial Real Estate Transactions," Law and Business Review of the Americas, Fall "Basic Issues for Foreign Corporations Doing Business in California (Including California Taxation) and Reporting and Disclosure Requirements of Foreign Investors," February 4, Recent Seminars and Speeches The 2011 Offshore Voluntary Disclosure Initiative: How it Works and Who May Benefit," San Diego Chapter of the California Society of CPAs, San Diego, CA, June 17, The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 4-5, The USD School of Law- Procopio International Tax Institute, San Diego, CA, October 19-20, "Planeacion Fiscal Internacional de los Estados Unidos para Inversionistas Mexicanos," Asociación Nacional de Abogados de Empresa, México City, Mexico, August 27, "Aspectos Prácticos ante la Turbulencia Financiera Mundial," Asociación Nacional de Abogados de Empresa, Querétaro, August 12, 2009 "Aspectos de Tributación Internacional: La Inversión USA-Mex, Reglas Anti-abuso, y USA-Mex International Tax Relevant Issues," Asociación Nacional de Abogados de Empresa, México City, Mexico, June 29, Investing in Mexican Real Estate, Puerto Vallarta, Mexico, October 25, The USD School of Law- Procopio International Tax Institute, San Diego, CA, May 1-2, "Surprise! You have a Foreign Trust!" Annual Meeting of the California Tax Bar and California Tax Policy Conference, November 2, Investing in Mexican Real Estate Conference, San Diego, CA, February 17, The USD School of Law- Procopio International Tax Institute, San Diego, CA, February 15-16, Fiscalización de Operaciones Internacionales, March 15-16, Investing in Mexican Real Estate Conference, San Diego, CA, February 25, The USD School of Law- Procopio International Tax Institute, San Diego, CA, February Growth Strategies- Building Blocks for Successful Ventures, CONNECT, San Diego, CA, January 24, The Boogey Man - Informational Reporting of International Transactions and the Hefty Penalty Provisions, 8 th Annual
7 San Diego Tax and Accounting Institute, November 11, "U.S. International Tax and Legal Implications of Maquiladora Operations," May 27, "What to do when your client didn't 'Check the Box'?" San Diego County Bar Association Taxation Section, San Diego, CA, September 9, 2003.
Patrick W. Martin, Partner
Patrick W. Martin, Partner Practice Areas Tax International Law Private Client Admissions California District of Columbia Texas Foreign Languages Spanish Professional Summary Direct Phone 619.515.3230
More informationIndian U.S. Tax Planning
Indian U.S. Tax Planning STEP Silicon Valley Palo Alto, CA January 22, 2014 Mahesh Kumar mahesh.kumar@nishithdesai.com Brian br@rowbotham.com Peter Trieu ptrieu@rowbotham.com & Company 101 2nd Street,
More informationDestination USA or the Round Trip Experience for Some! Immigration & Tax Planning
American Chamber of Commerce in Hong Kong Destination USA or the Round Trip Experience for Some! Hong Kong January 18, 2013 Immigration & Tax Planning AmCham Immigration & Tax Planning Table of Contents
More informationMEXICO S FLAT TAX (IETU) AND HOW IT AFFECTS U.S. INVESTORS IN MEXICAN REAL ESTATE PROJECTS. By Enrique Hernandez-Pulido 1
MEXICO S FLAT TAX (IETU) AND HOW IT AFFECTS U.S. INVESTORS IN MEXICAN REAL ESTATE PROJECTS Introduction. By Enrique Hernandez-Pulido 1 As of January 1, 2008, a new Flat Tax know as IETU 2 came into effect
More informationPre-Immigration Income Tax Planning
PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors Pre-Immigration Income Tax Planning By Richard S. Lehman Esq. TAX ATTORNEY www.lehmantaxlaw.com Richard S. Lehman Esq.
More informationSeth J. Entin Shareholder Tax entins@gtlaw.com Direct: +1 305.579.0615
Seth J. Entin Shareholder Tax entins@gtlaw.com Direct: +1 305.579.0615 Miami 333 SE 2nd Avenue Suite 4400 Miami, FL 33131 T +1 305.579.0500 F +1 305.579.0717 Seth J. Entin concentrates his practice in
More informationU.S. Tax & Legal Consequences for Foreigners & Potential Residents
Eduardo Ed R. Arista, CPA, Esq. Ed@AristaLaw.com 2655 Le Jeune RD, 5 th Fl Coral Gables, FL 33134 PH: (305) 444-7662 Fax: (305) 444-7275 U.S. Tax & Legal Consequences for Foreigners & Potential Residents
More informationMarch 28, 2012 India Tax Update
Silicon Valley March 28, 2012 India Tax Update Brian br@rowbotham.com (415) 433-1177 www.rowbotham.com U.S. Tax Reporting Challenges IRS Forms Penalties 5471 Foreign Corporation $10k per year per omission
More informationNuts & Bolts of Cross Border Tax Issues
Nuts & Bolts of Cross Border Tax Issues Central Arizona Estate Planning Council November 2, 2015 Presented by: Certified Public Accountant Attorney at Law 1 Overview What is an International Tax Practice?
More informationPre-Immigration Tax Planning
Pre-Immigration Tax Planning Safeguarding The Immigrant s Financial Interests Prior to Residency By Richard S. Lehman & Associates Attorneys at Law Pre-Immigration Tax Planning Safeguarding The Immigrant
More informationGary P. Tober. Owner - Seattle. gtober@gsblaw.com 206. 816.1415 Tel 206.464.0125 Fax
Gary P. Tober Owner - Seattle Second & Seneca Building 1191 Second Avenue 18th Floor Seattle, WA 98101-2939 gtober@gsblaw.com 206. 816.1415 Tel 206.464.0125 Fax Gary P. Tober has been practicing law for
More informationDavid C. Gair. Shareholder
David Gair is an established tax attorney who is Board Certified in Tax Law by the Texas Board of Legal Specialization. He offers his insight into tax matters on his blog, Texas Tax Talk. David focuses
More informationCHARLES RETTIG, Managing Partner Hochman, Salkin, Rettig, Toscher & Perez, P.C.
CHARLES RETTIG, Managing Partner Hochman, Salkin, Rettig, Toscher & Perez, P.C. Chuck Rettig specializes in tax controversies as well as tax, business, charitable and estate planning, and family wealth
More informationCURRICULUM VITAE. BRYAN C. SKARLATOS 212-808-8100 bskarlatos@kflaw.com. Adjunct Professor, Taxation New York University School of Law
CURRICULUM VITAE BRYAN C. SKARLATOS 212-808-8100 bskarlatos@kflaw.com PROFESSIONAL POSITIONS: Partner, Kostelanetz & Fink, LLP 7 World Trade Center New York, New York 10007 Adjunct Professor, Taxation
More informationTAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR
TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR Tax Benefits and Tax Traps By Richard S. Lehman & Associates Attorneys at Law TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR Tax Benefits and Tax Traps
More informationJerome A. Deener Partner
Jerome A. Deener Partner Roseland, NJ Tel: 973.994.7812 Fax: 973.992.9125 jdeener@foxrothschild.com Jerome is a nationally recognized estate planning attorney and tax litigator. He focuses his practice
More informationCertified Taxation Law Specialist, State Bar of California Board of Legal Specialization, 1991
KNEAVE RIGGALL Tax Law Pasadena, CA 91030 Adjunct Professor, Tax LL.M. Program (taught "Partnership Taxation I", "Corporate Taxation I" and, twice, "Taxation of S Corporations"), Loyola Law School, 2001
More informationPresented by: Erich C. Ferrari, Ferrari Legal, P.C.
Presented by: Erich C. Ferrari, Ferrari Legal, P.C. The Iranian Transactions Regulations is a comprehensive trade ban. It effects U.S. Persons U.S. Citizensà Dual Citizenship doesn t matter U.S. Permanent
More informationLatin America Practice Overview
Latin America Practice Overview Pillsbury Winthrop Shaw Pittman LLP www.pillsburylaw.com Latin America Practice Pillsbury Winthrop Shaw Pittman LLP Overview Decades of Experience in Latin America Pillsbury
More informationErik B. Wulff. Represented multi-brand global hotel company in connection with worldwide exclusive development ventures for several hotel brands
Erik B. Wulff Partner EDUCATION Indiana University (1976) J.D. cum laude Indiana University (1973) B.S. Member, Beta Gamma Sigma with distinction ADMISSIONS District of Columbia 500 Eighth Street, NW Washington,
More informationDouglas S. Stransky. Partner. www.sandw.com. Practices. Industries
Douglas S. Stransky Partner One Post Office Square Boston, MA 02109 T (617) 338-2437 F (617) 338-2880 dstransky@sandw.com Practices International Tax Tax International Private Investment Funds & Institutional
More informationACADEMIC APPOINTMENTS
Curriculum Vitae MICHAEL S. KIRSCH Professor of Law Notre Dame Law School University of Notre Dame 3116 Eck Hall of Law 46556-4639 (574) 631-5582 mkirsch@nd.edu ACADEMIC APPOINTMENTS Notre Dame Law School,
More information& FINANCIAL SERVICES US TAX & FINANCIAL SERVICES ACROSS THE WORLD. ustaxfs.com
& FINANCIAL SERVICES US TAX & FINANCIAL SERVICES ACROSS THE WORLD Company Overview The US Tax & Financial Services specialist team of cross border advisors provides tax advice, guidance, planning and compliance
More informationFATCA (Foreign Account Tax Compliance Act): What American Investors Need to Know Now
FATCA (Foreign Account Tax Compliance Act): What American Investors Need to Know Now Article Summary This article examines the new FATCA law (Foreign Account Tax Compliance Act) and explains the significant
More informationROBERT E. DALLMAN Taxation
Taxation (414) 978-5362 / rdallman@whdlaw.com EXPERIENCE PROFILE Robert Dallman is a shareholder in the Milwaukee office of Whyte Hirschboeck Dudek and chair of the Federal Taxation Team. Mr. Dallman's
More informationDouglas S. Stransky. Partner. www.sandw.com. Practices. Industries
Douglas S. Stransky Partner One Post Office Square Boston, MA 02109 T (617) 338-2437 F (617) 338-2880 dstransky@sandw.com Practices International Tax Tax International Private Investment Funds & Institutional
More informationINTERNATIONAL PRACTICE
INTERNATIONAL PRACTICE Shulman Rogers' International Practice Group unites under one umbrella a wide variety of experience and resources to meet the international legal needs of our foreign and domestic
More informationRequest to Transfer Ownership and/or Change Beneficiaries
Allianz Life Insurance Company of North America PO Box 59060 Minneapolis, MN 55459-0060 Phone: 800.950.1962 Fax: 763.582.6006 allianzlife.com Request to Transfer Ownership and/or Change Beneficiaries The
More informationTax and Succession Planning for Immigration to the United States
Tax and Succession Planning for Immigration to the United States Michael J. Legamaro May 2011 1 Concerns Upon Moving to US Minimizing US income tax Minimizing US estate tax Managing State law considerations
More informationInternational Tax. Las Vegas, Nevada December 4-5, 2012
International Tax 4 th Annual Southwest Tax Conference Las Vegas, Nevada December 4-5, 2012 Brian Phillip Lau Cindy Hsieh br@rowbotham.com plau@rowbotham.com chsieh@rowbotham.com 101 2 nd Street, Suite
More informationTAX PRESENTATION. By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP
TAX PRESENTATION By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP 1 Table of Contents 1. Immigration Tax and EB-5 5 Planning (a) (b) (c) (d) (e) (f) Pre-departure planning
More informationState and Local Tax Practice
State and Local Tax Practice BakerHostetler s State and Local Tax team advises clients across the country with respect to complex state and local tax matters, including issues pertaining to income, sales
More informationProfessional Involvement of Linda Lau in the Immigrant Investor Arena
Professional Involvement of Linda Lau in the Immigrant Investor Arena o Guest speaker, Private Client Forum Americas Panel Discussion, Mental incapacity and cross-border planning for assets in multiple
More informationU.S. Taxation of Foreign Investors
U.S. Taxation of Foreign Investors By Richard S. Lehman & Associates Attorneys at Law Copyright 2004 Copyright by Richard S. Lehman Page 1 U.S. Taxation of Foreign Corporations And Nonresident Aliens General
More informationUS Citizens Living in Canada
US Citizens Living in Canada Income Tax Considerations 1) I am a US citizen living in Canada. What are my income tax filing and reporting requirements? US Income Tax Returns A US citizen residing in Canada
More informationHEIR UN-APPARENT: ESTATE PLANNING FOR U.S. BENEFICIARIES
HEIR UN-APPARENT: ESTATE PLANNING FOR U.S. BENEFICIARIES Jamie Golombek Managing Director, Tax & Estate Planning CIBC Private Wealth Management Estate planning involves consideration of who should benefit
More informationScott F. Hesse Partner International Tax Services
Scott F. Hesse Partner International Tax Services Tel.: +1 (313) 394-6337 Fax.: +1 (813) 329-9654 Mobile: +1 (248) 396-4159 scott.f.hesse@us.pwc.com Scott leads the International Tax Services Practice
More informationNew Reporting Requirement for Foreign Bank Accounts and Assets
TAX & BUSINESS PLANNING IN THE NEWS February 2012 New Reporting Requirement for Foreign Bank Accounts and Assets A Polsinelli Shughart Update What is a Foreign Financial Asset Who Must File... 2 Filing
More informationU.S. Taxation and information reporting for foreign trusts and their U.S. owners and U.S. beneficiaries
Private Company Services U.S. Taxation and information reporting for foreign trusts and their U.S. owners and U.S. beneficiaries United States (U.S.) owners and beneficiaries of foreign trusts (i.e., non-u.s.
More informationTHE IRS RACE FOR INTERNATIONAL TAX COMPLIANCE
Today s session THE IRS RACE FOR INTERNATIONAL TAX COMPLIANCE Wednesday, March 27, 2013 1:00 to 2:30 pm EST Speakers Steve Waserstein, Partner, WNF Law, P.L. Waserstein Nunez & Foodman Daniel Foodman,
More informationAVOIDING UNINTENDED ESTATE PLANNING Tax Section. Friday, June 19, 2015 3:30 p.m. 4:30 p.m.
AVOIDING UNINTENDED ESTATE PLANNING Tax Section Michelle Rosenblatt Richards Rodriguez & Skeith Austin John Hunter The Blum Firm, PC Dallas Ivan Ramirez Law Office of Ramirez and Parenti San Antonio Friday,
More informationYour Target Market. Taking Your Company Global. International Tax & Accounting Services
Your Target Market Taking Your Company Global & Company www.rowbotham.com (415) 433-1177 consulting@rowbotham.com San Francisco Silicon Valley Associated Firms Worldwide International Tax & Accounting
More informationOFFSHORE INVESTMENT U.S. INTERNATIONAL TAX PLANNING AN ASIAN PERSPECTIVE. June 9th and 10th, 2010 SHANGHAI
OFFSHORE INVESTMENT U.S. INTERNATIONAL TAX PLANNING AN ASIAN PERSPECTIVE June 9th and 10th, 2010 SHANGHAI Harriet Leung hleung@rowbotham.com Brian br@rowbotham.com & Company LLP 101 Second Street, Suite
More informationMy client s a US citizen resident in the UK, what do I need to know?
My client s a US citizen resident in the UK, what do I need to know? So if my client s estate is worth less than the Credit Amount, my client has no reason to worry? Unfortunately, it isn t that simple.
More informationRoddy Sage, Executive Chairman Equiom Hong Kong
Roddy Sage, Executive Chairman Roddy is an associate member of the Institute of Taxation, with over thirty years experience in accounting, international tax planning and investment structuring, enhanced
More informationU.S. TAX IMPLICATIONS OF FOREIGN INVESTMENT IN U.S. REAL ESTATE
OCTOBER 9, 2003 U.S. TAX IMPLICATIONS OF FOREIGN INVESTMENT IN U.S. REAL ESTATE By Patrick W. Martin, Esq. Procopio, Cory, Hargreaves & Savitch LLP There are several different reasons why non-u.s. citizens
More informationYour Taxes: IRS grants 3-week extension for its tax-amnesty program
Your Taxes: IRS grants 3-week extension for its tax-amnesty program Sep. 22, 2009 KEVIN E. PACKMAN and LEON HARRIS, THE JERUSALEM POST This article is an urgent update for US taxpayers... and it comes
More informationHow To Get A Job As A Construction Attorney In California
DALE A. ORTMANN SHAREHOLDER PHONE 626.440.5200 FAX 626.796.0107 EMAIL ortmann@huntormann.com OVERVIEW EXPERIENCE Mr. Ortmann is a senior shareholder and co-founder of Hunt Ortmann, with more than 30 years
More informationUS Taxpayers Participating in Non US Retirement Plans: When is There an FBAR or FATCA Reporting Obligation?
February 29, 2012 Authors: Anubhav Gogna and David W. Powell If you have questions, please contact your regular Groom attorney or any of the attorneys listed below: Anubhav Gogna agogna@groom.com (202)
More informationThe Mexican Tax Authorities Man Up The new tax audit tools now available to the Mexican government
The Mexican Tax Authorities Man Up The new tax audit tools now available to the Mexican government Abel Francisco Mejia Cosenza May 2014 New Tools for International Tax Enforcement 1. Relevant Issues of
More informationROGERS JOSEPH O'DONNELL
415.956.2828 (t) Robert Dollar Building 415.956.6457 (f) 311 California Street, 10th Flr. San Francisco CA 94104 ROGERS JOSEPH O'DONNELL 202.777.8950 (t) Victor Building 202.347.8429 (f) 750 9th Street,
More informationPRIVATE CLIENT BRIEFING:
PRIVATE CLIENT BRIEFING: I M A US CITIZEN RESIDENT IN THE UK, WHAT DO I NEED TO KNOW? JANUARY 2013 Almost uniquely, the US taxes its citizens (and Green Card holders) on a worldwide basis regardless of
More informationLegal, Government Affairs & Business Consultant
Frank S. Ioppolo, Jr. Managing member Ioppolo Law Group, PLLC 1525 International Parkway Suite 4071 Lake Mary, FL 32746 (407) 444-1004 frankjr@ioppololawgroup.com www.ioppololawgroup.com Legal, Government
More informationIncreased IRS Tax Compliance Involving U.S. Citizens/Green Card Holders in Israel
Increased IRS Tax Compliance Involving U.S. Citizens/Green Card Holders in Israel October 2012 Tax Seminar Stuart M. Schabes, Esquire Ober, Kaler, Grimes & Shriver smschabes@ober.com 410-347-7696 (U.S.)
More informationTax & Legal Issues for Foreigners Investing in U.S. Real Estate
Tax & Legal Issues for Foreigners Investing in U.S. Real Estate Eduardo Ed R. Arista, CPA, Esq. Ed@AristaLaw.com Notice: The following slides consist of general information, and are not meant to be used
More informationDelivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad
Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad OGLE INTERNATIONAL TAX ADVISORS www.ogleintltax.com OUR INTERNATIONAL TAX PRACTICE INCLUDES BOTH CPAS AND ATTORNEYS WITH BIG
More informationShari A. Levitan. Boston T 617.854.1405 F 617.523.6850 shari.levitan@hklaw.com
Shari A. Levitan Partner Boston T 617.854.1405 F 617.523.6850 shari.levitan@hklaw.com Related Practices: Wealth Planning and Preservation Private Companies Private Wealth Services Trusts, Estates and Fiduciary
More informationIncome Tax and Social Insurance
The Global Employer: Focus on Global Immigration & Mobility Income Tax and Social Insurance An employee who works abroad is always concerned about the possibility of increased income taxation and social
More informationMay 2013. Dennis N. Brager, Esq. Upcoming Events. Greetings,
Thank you for your interest. You may unsubscribe if you no longer wish to receive our emails. May 2013 Greetings, I'll be speaking at an American Bar Association Section of Taxation webinar on "Administrative
More informationFrequently Encountered Taxation Issues to Consider
AMERICAN IMMIGRATION LAWYERS ASSOCIATION 21 May 2015 Frequently Encountered Taxation Issues to Consider Patrick W. Martin Procopio, Cory, Hargreaves & Savitch LLP 525 B Street, Suite 2200 San Diego, CA
More informationTop Ten Reasons to Use the U.S. as a International Tax & Residency Haven
New Haven New York Geneva Top Ten Reasons to Use the U.S. as a International Tax & Residency Haven Greenwich London Speaker: Ivan A. Sacks, Esq. Chairman, Withersworldwide Partner, Withers Bergman LLP
More informationTax and Legal Issues for Canadian Snowbirds: What you need to know
Tax and Legal Issues for Canadian Snowbirds: What you need to know Steven Sitcoff T: 514 875-3561 ssitcoff@spiegelsohmer.com October, 2014 Disclaimer What follows is for general informational purposes
More informationALI-ABA Topical Courses Income Tax Provisions of the New Federal Legislation January 18, 2011 Telephone Seminar/Audio Webcast
ALI-ABA Topical Courses Income Tax Provisions of the New Federal Legislation January 18, 2011 Telephone Seminar/Audio Webcast PROGRAM SCHEDULE FACULTY PARTICIPANTS FACULTY BIOGRAPHIES STUDY MATERIALS TABLE
More informationJune 2013. Dennis N. Brager, Esq. Upcoming Events. Greetings!
Thank you for your interest. You may unsubscribe if you no longer wish to receive our emails. June 2013 Greetings! All U.S. individuals and entities who have a financial interest in or signatory authority
More informationTHE IMPORTANCE OF INTERNATIONAL TAX AND ESTATE PLANNING By: Avi Z. Kestenbaum and K. Eli Akhavan
THE IMPORTANCE OF INTERNATIONAL TAX AND ESTATE PLANNING By: Avi Z. Kestenbaum and K. Eli Akhavan The current global economic environment demands that legal, accounting and financial professionals be well
More informationMSEA Annual Mini Workshop Events
MSEA Annual Mini Workshop Events Business Law for Tax Professionals Topics Speaker Date Before Aug 1 After July 31 Frank Acuña, Attorney August 11, 2012 $60 $75 FBAR/FATCA & Individual International Taxation
More informationSALT LAKE CITY ESTATE PLANNING COUNCIL
SALT LAKE CITY ESTATE PLANNING COUNCIL October, 2011 Robert G. Alexander, Esq. JD, LL.M., AEP, EPLS Alexander Law Offices, S.C. 933 N. Mayfair Road Suite 301 Milwaukee, WI 53226 (414) 476-5020 FAX (888)
More informationNewsLetter Asesoría Financiera, S.A.
NewsLetter Asesoría Financiera, S.A. NEWSLETTER Nº 9/2015 (28 January 2015) Gal.la Sánchez Vendrell. Partner. Lawyer. CEO Tax amnesty for American citizens resident in Spain The US is one of the few countries
More informationALI-ABA Course of Study Estate Planning for the Family Business Owner
597 ALI-ABA Course of Study Estate Planning for the Family Business Owner Cosponsored by the ABA Section of Real Property, Trust and Estate Law and the ABA Section of Taxation July 7-9, 2010 Chicago, Illinois
More informationU.S. Taxation of Foreign Investors
PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors U.S. Taxation of Foreign Investors Non Resident Alien Individuals & Foreign Corporations By Richard S. Lehman Esq. TAX
More informationCharles J. Lavelle Senior Partner Partnership Board Member clavelle@bgdlegal.com
Areas of Concentration Chaz is a member of the Tax & Employee Benefits practice group and a member of the firm's Partnership Board. He is primarily engaged in federal tax controversy work, but also has
More informationMexican Tax Law. Value Added Tax (VAT) is assessed on the consummation within the Mexican territory of the following types of transactions:
Mexican Tax Law By: Benjamin C. Rosen brosen@rosenlaw.com.mx Last Update: September 2006 INTRODUCTION Mexican companies (including subsidiaries of foreign companies), as well as permanent establishments
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features: Dean C. Berry, Partner, Cadwalader Wickersham & Taft, New York
Presenting a live 90-minute webinar with interactive Q&A Estate Planning Involving Resident and Non-Resident Aliens Navigating Estate, Gift and GST Tax Rules, and Leveraging Estate and Lifetime Gifting
More informationPersonal and Professional Resume of Gary Victor Dubin
Personal and Professional Resume of Gary Victor Dubin Attorney at Law Dubin Law Offices Harbor Court Suite 3100 55 Merchant Street Honolulu, Hawaii 96813 telephone: (808) 537-2300 facsimile: (808) 523-7733
More informationBIOGRAPHY OF ALICE A. SALVO
BIOGRAPHY OF ALICE A. SALVO ALICE A. SALVO holds an advanced Law Degree (L.L.M) in Estate Planning and has 29 years of experience in Probate, Estate Planning and Elder Law. She is AV rated, the highest
More informationWebinar: Next Generation ACO Implications: Impact of the New CMS ACO Model
Webinar: Next Generation ACO Implications: Impact of the New CMS ACO Model a HealthcareWebSummit Event, 1PM Eastern, Wednesday, April 22nd, 2015 Individual Registration Fee: $195. Post-Event Materials:
More informationU.S. Inbound Tax Services
TAX U.S. Inbound Tax Helping foreign companies achieve tax-efficiency in their U.S. operations kpmg.com 2011 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network
More informationValue through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser
Value through Wealth Planning - Key trends in Prof. Pierre-Marie Glauser Introduction (1) Wealth Management & Taxes Funds are Not declared Declared No taxes due Tax planning not necessary Relevant tax
More informationJULIE GOODWIN WEBER 267 Kentlands Blvd, Suite 250 Gaithersburg, Maryland 20878 julie.weber@goodwinweberlaw.com (301) 850-3387
EDUCATION University of Maryland School of Law, Baltimore, MD Juris Doctor, with honor, May 2005 GPA: 3.83/4.33 Class Rank: 7/223 Order of the Coif Journal: The Business Lawyer, Associate Articles Editor
More informationEB-5 Investor Visa and U.S. Tax Issues
IVENER& FULLME LMER LLP I M M I G R A T I O N A T T O R N E Y S Taxing Decisions EB-5 Investor Visa and U.S. Tax Issues Mark Ivener and Gary S. Wolfe On September 3, 2011, the Los Angeles Times published
More informationInternational Wealth Management. The Use of International Trusts
The Use of International Trusts By Canadians A Growing Presence Miami Mexico (3) 2010 El Salvador Costa Rica 2010 Panama 2010 Peru (2) Bahamas (SPCG + Scotiatrust) Cayman Islands (SPCG + Scotiatrust) Barbados
More informationForeign Nationals Consumer Guide
Foreign Nationals Consumer Guide Policies issued by: American General Life Insurance Company (AGL), and The United States Life Insurance Company in the City of New York (US Life) members of American International
More informationDelivering U.S. International Tax Services to Global Clientele
Delivering U.S. International Tax Services to Global Clientele OGLE INTERNATIONAL TAX ADVISORS www.ogleintltax.com OUR INTERNATIONAL TAX PRACTICE INCLUDES BOTH CPAS AND ATTORNEYS WITH BIG 4 AND FORTUNE
More informationFarmers and Foreign Accounts
Farmers and Foreign Accounts Marc Lovell Tax School and Department of Agricultural and Consumer Economics University of Illinois August 9, 04 farmdoc daily (4):65 Recommended citation format: Lovell, M.
More informationCURRICULUM VITAE MARK L. HEFTER, JD, CPA, LLM (Taxation)
CURRICULUM VITAE MARK L. HEFTER, JD, CPA, LLM (Taxation) Mark L. Hefter is a Vice President of the American Technion Society (ATS). Mr. Hefter s principal responsibility is to work directly with prospects,
More informationAlthough income taxes are usually the focus of
November December 2009 Comparative Overview of U.S. and Mexican Federal Employment Taxes * By Patrick W. Martin and Abel Mejia Patrick W. Martin is a U.S. lawyer licensed in California and Washington,
More informationSTATE BAR OF CALIFORNIA TAXATION SECTION INTERNATIONAL TAX COMMITTEE 1
SEPTEMBER 2010 STATE BAR OF CALIFORNIA TAXATION SECTION INTERNATIONAL TAX COMMITTEE 1 PROPOSED GUIDANCE ON FBARS & FOREIGN PERSONS By Patrick W. Martin, Esq. Procopio, Cory, Hargreaves & Savitch LL Patrick
More informationToday s Discussion. Income and Estate Planning for the Inbound and Outbound Resident
Income and Estate Planning for the Inbound and Outbound Resident Joel H. Paget Ryan, Swanson & Cleveland, PLLC February 13, 2013 Today s Discussion Questions to Ask Before Coming to the U.S. The Difference
More informationHow To Invest In A Regional Center
Taxing Decisions EB-5 Investor Visa And U.S. Tax Issues Gary S. Wolfe and Mark Ivener EB-5 Investor Visa And U.S. Tax Issues Mark Ivener and Gary S. Wolfe On September 3, 2011, the Los Angeles Times published
More informationWebinar Login Information: To access webinar, cut and paste the room passcode and return to homepage pop up.
Webinar Login Information: To access webinar, cut and paste the room passcode and return to homepage pop up. Churches and Ministries: Understanding Tax Issues and IRS Enforcement Guidelines Webinar Date:
More informationALBANY LAW SCHOOL OF UNION UNIVERSITY, J.D., 1988 J. Francis Doyle Scholar
Contact Information Office: Hodgson Russ LLP 677 Broadway, Albany, New York 12207 Phone: 518-433-2443 Fax: 518-465-1567 Email: tcollura@hodgsonruss.com Education Experience ALBANY LAW SCHOOL OF UNION UNIVERSITY,
More informationPre-Immigration Tax Planning and Post-Immigration Tax Compliance for EB-5 Investors
Pre-Immigration Tax Planning and Post-Immigration Tax Compliance for EB-5 Investors Alan Winston Granwell DLA Piper Steve Trow Trow & Rahal, PC This presentation is offered for informational purposes only
More informationMICHAEL KENNEDY, FOREIGN LEGAL CONSULTANT & U.S. LAWYER U.S. TAX & ESTATE PLANNING FOR CANADIANS & U.S. CITIZENS LIVING IN CANADA MARCH 7, 2014
MICHAEL KENNEDY, FOREIGN LEGAL CONSULTANT & U.S. LAWYER M U.S. TAX & ESTATE PLANNING FOR CANADIANS & U.S. CITIZENS LIVING IN CANADA MARCH 7, 2014 MICHAEL KENNEDY, FOREIGN LEGAL CONSULTANT & U.S. LAWYER
More informationRESUMÉ BOYD S. LEMON. Nature of Practice
RESUMÉ BOYD S. LEMON Attorney and member of the California Bar since 1966; member, Bar of the United States Supreme Court, various United States Courts of Appeals, United States District Courts and United
More informationGraduate Tax Program University of San Diego School of law
Graduate Tax Program University of San Diego School of law The School of Law The University of San Diego School of Law is one of only 81 law schools in the country to have a chapter of the Order of the
More informationExpatriation - A Comparison of Tax Issues in the US & UK in an Increasingly Mobile World
Expatriation - A Comparison of Tax Issues in the US & UK in an Increasingly Mobile World Henry Christensen III Jay E. Rivlin www.mwe.com Boston Brussels Chicago Düsseldorf Frankfurt Houston London Los
More informationThe prospect of investing in U.S. real estate can be attractive for citizens of
in United States Real Estate It is critical that you educate yourself and consult with an experienced tax professional that specializes in international taxation such as the Esquire Group. The prospect
More informationPre-Immigration Planning
Estate Planners Day 2013 Estate Planning Council Pre-Immigration Planning Kathryn von Matthiessen Cantor & Webb, P.A. May 8, 2013 Resident/Nonresident Domiciliary/Nondomiciliary RESIDENT DOMICILIARY NONRESIDENT
More informationOvercoming the Challenge
TAX Overcoming the Challenge Transfer Pricing Dispute Resolution Services kpmg.com 2 Overcoming the Challenge: Transfer Pricing Dispute Resolution Services Given the importance of this issue to the tax
More informationBENEFITS & COMPENSATION INTERNATIONAL TOTAL REMUNERATION AND PENSION INVESTMENT
BENEFITS & COMPENSATION INTERNATIONAL TOTAL REMUNERATION AND PENSION INVESTMENT Proposed IRS Regulations Exempt Some Non-US Retirement Plans from FATCA David W. Powell and Anubhav Gogna David Powell is
More information