Foreign Foundations — What are they for US Tax Purposes?  Should I Care? Recent Court Case Lays it Out

Today’s post looks at the case of Rost v United States, No 119-CV-0607-RP 2021 BL 435976 (WD Tex., Austin Div., September 22, 2021).  In the Rost case, the Internal Revenue Service ("IRS") assessed close to USD597,000 in civil penalties for a US taxpayer’s failure to file IRS Forms 3520 and 3520-A, information reporting with regard … Continue reading Foreign Foundations — What are they for US Tax Purposes?  Should I Care? Recent Court Case Lays it Out

The Flexible “Foundation” – It’s Becoming a Thing!

Recently I was the guest speaker on Jimmy Sexton’s podcast discussing all things related to an entity called a “foundation”.  A foundation is a creature of a country’s statutory law, but foundations are not well understood in common law jurisdictions, such as the United States.  In the podcast, we looked at the difference between civil … Continue reading The Flexible “Foundation” – It’s Becoming a Thing!

Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates

Proud to announce publication of my article Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates in Tax Notes International (TNI) Vol. 98 No. 5 May 4, 2020. Available at no cost on SSRN. The article discusses the US tax treatment of the newest "foundations" … Continue reading Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates