Experience Category: Tax Planning

State Tax Nexus for Deployed Civilian Contractor

Research and analysis of state tax nexus statutes in multiple states relating to domiciliary test for civilian contractor long-deployed in Afghanistan.  Review of multiple state rules and weighing factors between different potential states on possible application of state-level tax to capital gains on sale of business property while overseas.

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.
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