As blockchain and cryptocurrency continue the transition from early adopters to mainstream traditional finance, it’s important to consider how IRS might apply traditional subpart F anti-deferral rules.

Internal Revenue Code Secs. 877A and 2801, related to individuals who relinquish U.S. citizenship or long-term permanent residence (green cards), have largely remained unchanged since taking effect in 2008.

The Great Wealth Transfer is already underway, with an estimated $124 trillion expected to shift between generations by 2048, according to Cerulli Associates.

Cost segregation has long benefited taxpayers with increased cash flow.

Simplistically, the Connelly v. United States case represents a pivotal decision impacting the estate tax .

The House adopted on April 10, 2025, the budget resolution previously approved by the Senate on April 5 that would allow permanent extension of the expiring provisions in the Tax Cuts and Jobs Act (TCJA), as well as an additional $1.5 trillion for tax cuts to address President Trump’s campaign promises.

This guide is intended for individuals considering a move to the United States, especially those individuals with substantial wealth who need to organize their financial affairs before landing. It provides insight into topics on tax planning for foreign individual,s including residency, pre-residency income tax planning, pre-domicile transfer tax planning, and state and local tax.

The QSBS provisions were enacted into law in 1993

While interest rates and the rate of inflation have trended downward over the last couple of years, both measurements remain high relative to recent cycles. With the 2025 tax season upon us, successful business tax planning requires being informed and adaptable to the dynamic economic environment.