Using real-life, pragmatic examples and their vast experience in trust and estate planning, Hal J. Webb, Jennifer Wioncek, and Paul D'Alessandro, Jr. provided a comprehensive look at U.S. federal tax and succession planning for non-U.S. persons investing in U.S....
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Hal Webb and Jennifer Wioncek participate in a panel discussion titled So Your Guy Didn't Win the Election: Time to Expatriate? as part of the 39th Annual International Tax Conference hosted by The Florida Bar Tax Section and the Florida Institute of Certified Public Accountants.
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.