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Check the Box Elections for Non-U.S. Business Entities

Publisher: Journal of International Tax, Trust and Corporate Planning
October 10, 2017
Day Pitney Author(s) Stephen Ziobrowski Carl A. Merino

Stephen Ziobrowski, Andrew Wogman, Carl Merino, Aaron Kriss and Matthew Woodbury authored an article, "Check the Box Elections for Non-U.S. Business Entities," which was published in the Journal of International Tax, Trust and Corporate Planning. The article focuses on the use of entity classification elections, commonly known as 'check the box' elections, for non-U.S. business entities. As the authors discuss, these elections, which may be made retroactively or prospectively, are very useful in permitting U.S. taxpayers to invest in non-U.S. business entities without running a foul of punitive tax rules designed to discourage U.S. persons from hiding assets in offshore corporations or deferring U.S. tax through offshore entities. Entity classification elections have numerous practical applications, which are discussed in depth.

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Day Pitney's Palm Beach Family Office Forum 2020 Update

Due to the COVID-19 pandemic, this year's annual Day Pitney Palm Beach Family Office Forum, which had originally been scheduled for April 28 and 29, has been postponed to hopefully be rescheduled for later this year.

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On January 31, David Waizer will be speaking at "Drafting Lasting Business Contracts: Simple, Powerful Strategies That Stand The Test of Time," a program and live webcast presented by the New Jersey Institute for Continuing Legal Education, a division of the New Jersey State Bar Association.

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Senior Associate Justin M. Hannan and Partner Stephen Ziobrowski were quoted in the Law360 Tax Authority article, "Carried Interest Regs Leave Uncertainty On Family Managers."

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Hedge Fund Law Report Covers Erik Bergman's Move to Day Pitney's Stamford, CT Office
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Hedge Fund Law Report covered Erik Bergman's move to Day Pitney's Stamford office in an article posted March 12.

Day Pitney Represents Pula Capital Management LP in Strategic Investment by Felton Group, LLC
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Day Pitney LLP represented Pula Capital Management LP (Pula), a newly formed investment manager based in Virginia, in connection with (i) the acquisition of a minority ownership interest in Pula by Felton Group, LLC (Felton Group), and (ii) an investment by Felton Group in Pula Capital Fund, LP, a newly formed fund managed by Pula that intends to employ novel mathematical techniques and a proprietary, systematic predictive model to trade a diversified long-short portfolio of liquid U.S. equities.
Related Professionals
Stephen Ziobrowski
Stephen Ziobrowski
Boston, MA
T: (617) 345 4648
Merino, Carl
Carl A. Merino
New York, NY
T: (212) 297 5829
New Jersey Hartford Stamford Greenwich New Haven West Hartford Boston
New York Washington, DC Boca Raton Delray Beach Miami West Palm Beach

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