On July 8, 2024, the ABA Sections of Taxation and Real Property, Trust and Estate submitted comments on the proposed regulations under Internal Revenue Code (IRC) §§ 643(i), 679, 6039F, 6048, and 6677 regarding transactions with foreign trusts and information reporting on transactions with foreign trusts and large foreign gifts.
The 16th Annual U.S. and Latin America Tax Practice Trends conference will take place at the Mandarin Oriental, Miami, from June 12 – 14, 2024. Kostelanetz LLP is a proud sponsor of the event; several members of the firm will be present as attendees, moderators, and panel participants. Wednesday, June
By Ian Weinstock and Heather Fincher For nearly thirty years, taxpayers have been waiting for the IRS to issue regulations related to foreign trusts and foreign gifts. Since 1996, when Congress enacted a myriad of provisions to prevent tax avoidance through the use of foreign trusts and gifts, taxpayers have
Heather Fincher will participate in a panel titled “Where in the World…? Recent Updates in International Information Return Caselaw and Practice” hosted by the D.C. Bar on January 24, 2024. The conference will be held virtually. Event Description: Tax controversy professionals – including the current National Taxpayer Advocate – have
Kostelanetz attorneys will participate in a variety of panels and presentations at the ABA Tax Section’s Virtual 2023 Fall Tax Meeting on October 16-20, 2023. Tuesday, October 17, 2023 2:30 pm – 3:00 pm: Michael Sardar presents on International Tax Enforcement during the “Reports of Subcommittees on Important Developments” section
Kostelanetz LLP is a proud sponsor of Heather Fincher‘s new podcast, “Powerful Professional Women.” The first two episodes of “Powerful Professional Women” feature conversations between Heather Fincher and Caroline Ciraolo. Episode 1, “On Connections with Caroline Ciraolo,” launched on July 31, 2023. Click here to listen to the full episode. Click here to watch the episode on
On August 22, 2023, Heather Fincher participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford. CPE Credit is offered for this event. Description: This course provides tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact
On May 25, 2023, Heather Fincher presents on a panel entitled, “What to do when Advisors Find Errors in International Tax Returns” at the Procopio International Tax Institute 2023 International Update: U.S. – Mexico Cross-Border Tax Issues. Description: Heather is moderating an engaging discussion of real-life hypos, common mistakes, and
In this CLE/CPE course, Heather Fincher provides tax professionals with an in-depth discussion of the challenges posed to U.S. businesses that must report their global intangible low-taxed income (GILTI). The panel provides tax professionals with guidance on the challenges of the GILTI rules and discusses calculating GILTI and the Section 250
