Day Pitney remains committed to providing quality legal counsel, while protecting our clients and employees, and transforming our communities into more just, equal and equitable spaces. For more information, please visit our COVID-19 Resource Center | Racial Justice and Equity Task Force.
Carl Merino, Dina Kapur Sanna and Seth Mersky co-authored an article, "Attribution After the TCJA: A Downward Spiral of Unintended Consequences," published by Trusts and Estates. The article focuses on the repeal of Internal Revenue Code Section 958(b)(4) as part of the Tax Cuts and Jobs Act of 2017 (TCJA). The repeal of this provision changed the rules for when ownership of stock of a foreign corporation can be attributed “downward” from a foreign shareholder, partner or beneficiary to a U.S. corporation, partnership trust or estate, causing many foreign companies that were not previously subject to the controlled foreign corporation (CFC) rules to become CFCs, with adverse tax consequences for both inbound and outbound investment structures.
The ABA recently published the 25th Edition of The Property Tax Deskbook.
Day Pitney Partner Dina Kapur Sanna was a panelist on the session, "Where Should I Locate My Structures?," at the Transcontinental Trusts International Virtual Conference.
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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Glenn Rybacki gives an in-depth summary on what domicile is and the preparations necessary for a potential audit in "Domicile Changes and Audits Increase in Connecticut," his latest entry in State Tax Notes.
On May 8, Amy Lonergan was a panelist on a webinar, "COVID-19 and Election Year Wealth Transfer Strategies," hosted by the Family Wealth Alliance.
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.