Insights

There are various ways to structure a foreign investment in US real property and each has its own advantages and disadvantages (see below for a link to a previous blog post on this topic). A frequently chosen structure is a pass-through or fiscally transparent structure which, very generally, has income tax…

In CNT Investors, LLC v. Commissioner, 114 T.C. No. 11 (2015), the Tax Court recently held that a retired mortician reasonably relied on the advice of his long-time corporate and estate planning attorney in participating in a Son-of-BOSS tax shelter transaction to divest real estate holdings. Although the court ruled that…

During the course of an audit of a partnership for employment tax matters, an issue arose as to whether the tax partnership (which has numerous partners) was subject to the unified partnership audit and litigation provisions of TEFRA (the Tax Equity and Fiscal Responsibility Act of 1982). Representing the partnership,…

Williams Parker acted as tax counsel for a client in connection with a $3 million income tax dispute with the Internal Revenue Service. The dispute involved the proper allocation of income among entities in a multi-entity corporate structure where some of the entities were C corporations and others were pass-through…

When families with foundations relocate to Florida, they oftentimes want to relocate their foundations too. There are several different structures for accomplishing the relocation (i.e., change in state of domicile) of a foundation or other non-profit corporation. For a variety of reasons, the best structure is oftentimes a domestication, which is…