Experience Category: International

Research on New Self-Created Intellectual Property Taxation Rules

Research on conflicting laws relating to taxation of self-created intellectual property; memo presenting analysis based on maxims of statutory construction and legislative intent relating to new provision of law conflicting with remaining existing provision of law.  Strategic advice to client RE: same.

International Estate Planning on RE Held Through S Corporations

Advice and planning relating to US real estate assets held in S Corporations by international family holding EU real estate as well.  Domicile questions, allocations and implications of renunciation of status on testamentary transfers to US citizens.  Optimization of US exemption amount in relation to overall international estate planning including application of international treaty network and credits for local estate taxes levied upon death.

FIRPTA Application to Renewables Project

Research and advice on application of FIRPTA to utility-scale renewable solar project.  Analysis of percentage of project attributable to elements of project categorized as real property under FIRPTA rulings, advice to client RE: same.
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