The levying of tax penalties stood in a recent federal appeals court decision on whether a private foundation was a foreign trust subject to such penalties. In the Rost v. U.S., the U.S. Court of Appeals for the Fifth Circuit upheld tax penalties against U.S. citizen John Rebold, who failed to report his personal-use Liechtenstein “Stiftung” (a non-charitable private foundation) as a foreign trust. The decedent Rebold formed the Enelre Foundation in 2005 for the general support and education of him...

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Key Takeaways Midterm elections rarely dictate a clear shift in the fiscal policy landscape, and the 2022 elections are no different. Fiscal policy has been expansionary during the recent period of unified political leadership. A divided government would likely thwart major legislative agendas from either side of the aisle. The health of the U.S. economy will be far more pivotal for commercial real estate over the next couple of years. The Federal Reserve has a bigger say in its...

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With the help of our members, this thought-leadership series explores the acceleration of “digitalization” due to COVID-19 on both sides of the Atlantic, and across various industries. Today, we present Tim Roberts, Managing Director & UK Country Co-Head at ALIXPARTNERS, and based in London. He will address: “VR = Virtual Risks? Understanding the risks - and opportunities - in the metaverse”. Many people are trying to get their heads around the metaverse and figure out whether it will be life-changing,...

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The U.S. Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) on Oct. 28 announced $5 billion in New Markets Tax Credit (NMTC) awards with the goal of economically revitalizing low-income communities across the country. Particular outcomes the CDFI Fund hopes to achieve with this round of awards include job creation associated with investments in manufacturing, retail, and technology, as well as greater access to housing and public facilities such as health, education, and childcare for low-income...

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An estate plan is a crucial strategy that should be devised for the transfer of high-net-worth individuals’ property, whether during their lifetime or, often, after their death. At Cea Legal, we strive to create “bespoke” estate plans for each client. The task begins with understanding our clients’ long-term goals: making gifts or enjoying their wealth during their lifetime; optimal tax allocations; transfer assets at death and reducing probate proceedings; providing for disability; making charitable contributions. Before devising an effective strategy, we...

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The 27th United Nations Climate Change Conference (COP 27) will soon kick off in Sharm El-Sheikh, Egypt. This year’s COP, which will take place from 6-18 November, will bring parties from across the globe together for discussions on how to tackle climate change and accelerate action towards the goals of the Paris Agreement. Under the Egyptian Presidency, the goal of COP27 is to move from negotiations and planning to actual implementation. The immediacy and dangers of the climate crisis requires “bold and...

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What FTI Cybersecurity expert Greg Berkin knows about setting up (and knocking down) dominos might just keep your organization from being hacked. We’re all familiar with the art and science of domino toppling from our childhoods. You set up dominos on their tail ends and knock down the first in line to create a chain reaction. A successful “run” is the uninterrupted (and gratifying) flow of toppling tiles to the very last one. On the biggest stages, the most spectacular domino...

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As part of its review of the future of the China 301 tariffs, the Office of the U.S. Trade Representative (“USTR”) is soliciting public comments as to the effectiveness of these tariffs (or other actions that could be taken) and the corresponding effects on the U.S. economy.  In a prior action, the USTR sought input from the domestic industry as to whether the 301 action should remain in effect. In connection with this stage of its review, the USTR will...

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The EU's Digital Markets Act (DMA) enters into force on 1 November 2022. It promises to be one of the most significant developments in the history of EU regulation, ushering in a new era for technology companies operating in the EU. In this communication we set out the background to the DMA, the companies whose services will be affected, the obligations that they will have, the consequences of non-compliance and the next steps in the DMA's application. What are the...

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The Internal Revenue Service has received another thumbs-up from a federal court in the agency’s new passion to root out cryptocurrency tax fraud. The U.S. District Court in the Central District of California authorized the IRS to serve a John Doe summons on Los Angeles-based OX Labs Inc., d/b/a SFOX and its subsidiaries. SFOX is a cryptocurrency prime dealer for professional traders and institutional investors and has more than 175,000 registered users. The IRS wants information about U.S. taxpayers who conducted...

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