May 16, 2018
Tax Cuts and Jobs Act: How Should U.S. Individuals Restructure Foreign Corporation Ownership?
Paul Marcotte was a panelist for STEP Mid Atlantic on May 16, 2018.
The Tax Cuts and Jobs Act significantly revised the international tax provisions of the Internal Revenue Code. For U.S. corporations owning 10% or more participations in foreign corporations engaged in active businesses, deferral is effectively ended, and a foreign corporation’s earnings are subject to worldwide taxation, based on a split rate system, or tax exemption. For U.S. individuals, a foreign corporation’s active business profits are subject to worldwide taxation at ordinary income tax rates or U.S. tax deferral. Simply stated, prior law structures no longer work for individuals. The presentation summarized the new international tax regimes and proactive planning strategies. There was also an interactive discussion and Q&A.
November 19, 2020
Paula Calimafde, Michelle Chapin, Tracey Coates, Deborah Cohn, Glenn Cooper and Eva Juncker were all selected to Washingtonian's Top Lawyers list for 2020.Read More
The COVID-19 pandemic has disrupted “business as usual” in many ways. People and businesses have been focusing on safety measures and efforts to maintain financial...Read More