Analysis of potential 199A deduction for receipts of income in and relating to cryptocurrency activities.  Review of (limited) available literature on subject.  Structuring income receipt via. entities to maximize deferral possibilities on retirement planning pre-filing deadline and advice on proper reporting for receipt of cryptocurrency income.

Tax analysis and strategic planning involving US citizen living in UK with multiple jurisdictional income streams.  Interplay of sub-chapter S strategies with Limited Company strategies (HMRC) and implications of the application of CFC or FPHC rules to UK-based strategies, along with international discussions of multi-tier strategic individual tax planning.

Discussions and analysis of proper tax reporting of ownership of property and entities in the context of ongoing litigation of probate of estate.  Review of both tax rules and prima facie application of both EPTL provisions and application of trust documents in play with respect to entity ownership.  Guidance on best course of action both in relation to tax reporting and to implications of tax reporting on Surrogate’s Court presentation of income and ownership information.