Tax

On February 8th, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative for taxpayers with undisclosed income in foreign bank accounts to come forward and get current with their taxes. By coming forward voluntarily, taxpayers can generally avoid criminal prosecution and pay a reduced...

On February 14, 2011, the Obama administration released its proposal for the FY 2012 budget. Several tax policy issues pursued by the Obama administration in previous years were again included in the budget proposal, including the taxation of “carried interests” as ordinary income.The movement to...

In late September of this year, the federal government passed the Small Business Jobs Act of 2010 (“SBJA 2010”). Among other things, SBJA 2010 provides for an exclusion of 100% of the gain realized on the sale of certain qualified small business stock (“QSBS”) held...

On October 14, President Obama signed H.R. 946, the Plain Writing Act of 2010 (the “Act”) into law. The Act requires all government agencies, including the IRS, to draft “covered” public documents in “plain writing.”“Covered” documents include documents that – (i) are necessary for obtaining...

On September 27, 2010 the President signed the Small Business Jobs and Credit Act of 2010 (the “Act”) into law.  The Act provides for more than $40 billion worth of tax benefits aimed to support economic growth among small businesses. In summary, the Act provides...

I have always been impressed with the Swiss government’s longstanding capacity for discretion – much like the governmental equivalent of a friend that can keep a secret.Unfortunately, as we have been discovering, there are some very good reasons that Swiss account holders have demanded...

On March 18, 2010 the President signed the Hiring Incentives to Restore Employment Act of 2010 (“HIRE”) into law.  HIRE provides $13 billion worth of tax incentives to businesses in the form of –(1) Temporary payroll tax relief for employers who hire individuals that have...

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