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Paul J. D'Alessandro, Jr. and Hal Webb cover some of the most common mistakes made by international private clients and traps that practitioners should be on the lookout for.
This article briefly summarizes the attribution rules applicable to partnerships and corporations under Section 318 and provides some practical tips for dealing with the rules.
As we approach the final two months of 2020, it is a good time to review a topic that has, perhaps not coincidentally, been coming up more and more frequently during this unusual year: the U.S. tax implications of renouncing U.S. citizenship or residency – a process formally known as expatriat...