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Author Archives: Bradley Albin

About Bradley Albin

Attorney with 15 years inbound and outbound corporate tax consulting and compliance experience; 2 years in Big 4 Mergers and Acquisitions Group; substantial work with hedge funds and private equity funds. Big 4 (Arthur Andersen, Deloitte, PwC).

IRS Update: Does your partnership agreement need to be revised?

Last month, the Internal Revenue Service (IRS) finalized proposed regulations on the designation and authority of a partnership representative under the centralized partnership audit procedures that went into effect for tax years after December 31, 2017. This article addresses some of the key points of the final regulations. Prior to discussing these regulations, we thought it […]

US Tax Reform: Final TCJA Highlights

On December 20, 2017, Congress passed H.R. 1 – the Tax Cuts and Jobs Act (TCJA) – providing for the largest changes to the US tax code since 1986 and President Trump signed the bill into law on December 22, 2017. As we have done previously, we have highlighted the changes made to US Federal […]

US Tax Reform: Senate Interpretation

This past weekend, the US Senate passed H.R. 1 – the Tax Cuts and Jobs Act – providing for the largest changes to the US tax code since 1986. The following is a list of “highlights” in the legislation (along with differences from the House bill passed on November 16, 2017): Corporate Tax Provisions Much like […]

Tax Reform: Trump v1 Highlights

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released their initial attempt at tax reform. The document is entitled “Unified Framework for Fixing Our Broken Tax Code.” Some of the highlight items include: Consolidating the current seven income tax brackets into three brackets […]

You can run but can you still hide?

PLEASE NOTE: For new rules concerning single member foreign owned LLC’s please also read our post  New IRS Reporting Requirements Foreign-owned US LLCs. With the passage and implementation of the Foreign Account and Tax Compliance Act (FATCA), much has been made of the US government’s attempt to crack down on its citizens’ use of accounts […]

Recap: UK Financial Institutions affected by the new US – UK FATCA Agreement

As we posted yesterday, the US and UK governments on September 14, 2012, entered into a bilateral agreement to improve international tax compliance, combat tax evasion and to implement FATCA.  In addition to the procedural requirements relating to what both US and UK financial institutions as well as the US and UK governments must to […]

FATCA: US – UK Sign Bilateral tax agreement

As previously discussed, the US has been working with foreign governments to Improve tax compliance, combat offshore tax evasion and help them to meet their obligations under the new Foreign Account Tax Compliance Act (FATCA).  Recently, model intergovernmental agreements have been proposed, with Switzerland and Japan signing FATCA agreements in June. The US and the […]

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