Seth J. Entin
As seen in:
Daily Business Review,
Law.com,
Law360,
JD Supra,
Mondaq,
Financial Advisor,
Daily Tax Report
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Articles by Seth J. Entin
Breaking The
To print this article, all you need is to be registered or login on Mondaq.com. The U.S. Department of the Treasury has issued proposed regulations (the Proposed Regulations) that would restrict foreign persons' ability to minimize U.S. tax through "conduit" financing arrangements. This Holland & Knight alert presents a brief overview of the 30 percent withholding tax and the current "anti-conduit" rules, then describes the key changes that the Proposed Regulations would make.
Breaking the "Equity Wall": Proposed Regulations Limit Chances to Minimize U.S. Withholding Tax | JD Supra
Highlights The U.S. Department of the Treasury has issued proposed regulations (the Proposed Regulations) that would restrict foreign persons' ability to minimize U.S. tax through "conduit" financing arrangements. This Holland & Knight alert presents a brief overview of the 30 percent withholding tax and the current "anti-conduit" rules, then describes the key changes that the Proposed Regulations would make.
INSIGHT: Foreign Investment in Distressed Debt-Achieving U.S. Tax Benefits While Avoiding Pitfalls
The economic troubles that many businesses are facing because of the coronavirus pandemic have given rise to significant interest by investors in acquiring (or investing in funds that acquire) distressed debt instruments. If certain conditions are met, foreign investors may earn interest income on debt issued by U.S. borrowers, and gain from the sale or retirement of these debt instruments, free of U.S. federal income tax.
Foreign Investment In Distressed Debt: Unique Tax Opportunities, But Beware Of Pitfalls
The economic troubles that many businesses are facing because of the coronavirus (COVID-19) pandemic have given rise to significant interest by investors in acquiring, or investing in funds that acquire, distressed debt instruments 1 This Holland & Knight alert discusses some key potential U.S. federal income tax 2 opportunities and challenges for foreign investors in U.S. distressed debt.
Distressed Debt Tax Opportunities For Foreign Investors
Law360 (May 15, 2020, 3:52 PM EDT) -- The economic troubles that many businesses are facing because of the coronavirus pandemic have given rise to significant interest by investors in acquiring, or investing in funds that acquire, distressed debt instruments.[1] This article discusses some key potential U.S. federal income tax[2] opportunities and challenges for foreign investors in U.S. distressed debt.
Foreign Investment in Distressed Debt: Unique Tax Opportunities, But Beware of Pitfalls | JD Supra
Highlights The economic troubles that many businesses are facing because of the coronavirus (COVID-19) pandemic have given rise to significant interest by investors in acquiring, or investing in funds that acquire, distressed debt instruments. Foreign investors may earn interest income on debt and may also earn income from the sale or retirement of debt issued by U.S. companies free of U.S. tax, if certain conditions are met.
Html.Raw(The 2020 Stock Market Crash And PFIC Status - Corporate/Commercial Law - United States)
To print this article, all you need is to be registered or login on Mondaq.com. Highlights The recent drop in stock prices resulting from the coronavirus (COVID-19) pandemic has put certain foreign corporations at greater risk of being classified as "passive foreign investment companies" (PFICs).
U.S. Income Tax Residence And The Coronavirus
To print this article, all you need is to be registered or login on Mondaq.com. Highlights With the unfortunate emergence and rapid spread of the coronavirus (COVID-19) pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States this year.
Mitigating The Unintended Tax Consequences Of Coronavirus
By Seth Entin March 26, 2020, 6:12 PM EDT Law360 (March 26, 2020, 6:12 PM EDT) -- With the unfortunate emergence and rapid spread of the coronavirus, there are many non-U.S. individuals who will be spending significantly longer than expected in the U.S. this year. A critical question is whether these individuals will be classified as U.S. residents for U.S. federal income tax purposes, referred to as U.S. income tax residents.
U.S. Income Tax Residence and the Coronavirus | JD Supra
With the unfortunate emergence and rapid spread of the coronavirus (COVID-19) pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States this year. A critical question is whether these individuals will be classified as U.S. residents for U.S. federal income tax purposes (referred to as U.S. income tax residents).
Tax Reform Presents Opportunities For Foreign Investors In U.S. Businesses
To print this article, all you need is to be registered or login on Mondaq.com. Highlights The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime, including many reforms that focus on multinational corporations. However, some lesser known TCJA provisions apply to foreign individuals.
Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Relief on Way to US Individuals Owning Stock in Controlled Foreign Corporations
(L to R) Seth Entin and William B. Sherman, Holland & Knight. The U.S. Department of the Treasury on March 4, released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a controlled foreign corporation (CFC). The proposed regulations (REG-104464-18) provide relief from some of the provisions of the U.S. tax reform that apply to individual U.S. citizens or tax residents and U.S. trusts and estates who own stock in a CFC.
Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed Regulations Would Minimize or Eliminate Some Adverse Consequences | Holland & Knight LLP - JDSupra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Welcome News for Non-US Persons Investing in US Businesses
On July 13, the U.S. Tax Court, issued a decision that is of major importance to non-U.S. investors. In Grecian Magnesite Mining, Industrial & Shipping v. Commissioner (Grecian), the court held that if a non-U.S. person sells an interest in a partnership that is engaged in business in the United States, the non-U.S. seller is not subject to U.S. federal income tax on the gain from the sale. By so holding, the Tax Court, in no uncertain terms, rejected a long-standing IRS ruling to the contrary.
Wednesday Deadline Approaching For Foreign Accounts
Mr. and Mrs. Doe, who are U.S. citizens, have an account with a foreign financial institution. The Does have never reported their ownership of or the income from this account on Schedule B of their U.S. federal income tax returns, and they have never filed Treasury Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts or FBAR), which they are required to do to disclose this account.
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