Freeman Law Tax Update: What a Biden Presidency Means for Your Federal Income...
With the election of Joe Biden, Freeman Law has already begun to review what a Joe Biden presidency could mean to its clients. And although many of determinations could potentially depend on results...
View ArticleU.S. Digital Service Providers with Mexican customers: Avoid being...
COVID times has brought us tough changes in our lives, and tax reform is one of them. In the U.S., the CARES Act provided relief to multiple sectors of the economy to alleviate the impact of the...
View ArticleWhat is a Trust?
Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is,...
View ArticleNotable Tax Takeaways from President Biden’s Budget
On March 28, 2022, President Joe Biden released his FY 2023 Budget of the U.S. Government (the “Budget”).[1] In a statement regarding the Budget, President Biden stated the following: My Administration...
View ArticleSection 245A Overview and Requirements
Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to...
View ArticleGain Recognition Agreements and Outbound Stock Transfers
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements Section 367(a) of the Internal Revenue...
View ArticleStrategies to Recharacterize Gain with Untaxed Foreign Earnings.
Using Untaxed Foreign Earnings to Recharacterize Gain from Section 311(b) Distributions or Section 964(e) Stock Sales Introduction: Pairing Section 311(b) Distributions or Section 964(e) Stock Sales...
View ArticleReviewing a Foreign Legal Structure
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S....
View ArticleIRAs Part II – Contributions and Distributions
This post is a follow-up to my previous post in which I discussed some of the basics concerning Individual Retirement Accounts (“IRAs”). It can be found here if you haven’t read that post yet. In...
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