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Attribution After the TCJA: A Downward Spiral of Unintended Consequences

Publisher: Trusts and Estates
October 24, 2019
Day Pitney Author(s) Carl A. Merino Dina Kapur Sanna Seth J. Mersky

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.

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Trusts & Estates End of Year Review 2021: Boston Bar Association

Christopher Voukides is a speaker at the Trusts & Estates End of Year Review 2021 sponsored by the Boston Bar Association on June 21.

June 21, 2021
Webinar Hosted By BBA
Anchin Executive Forum: The Changing Shape of Business in New York

Scott Clark, Chair of Day Pitney’s Multistate Tax Practice, is presenting on a virtual panel at the Anchin Executive Forum titled, “The Changing Shape of Business in New York” on June 9. 

June 9, 2021
Webinar hosted by Anchin Executive Forum
Till Death (And Qualified Trusts) Do Us Part
May 11, 2021

Andrew M. Nerney and Stephanie Eassa Rapp co-authored the article, "Till Death (And Qualified Trusts) Do Us Part," published by WealthManagement.com.

IRS Issues Final Carried Interest Regulations
April 12, 2021

Justin M. Hannan authored the article, "IRS Issues Final Carried Interest Regulations," on the Boston Bar Association's Trusts and Estates Blog.

Retroactive Tax Legislation and Gift Planning in 2021
March 25, 2021

Daniela P. Catrocho and Richard D. Sanders authored the article, "Retroactive Tax Legislation and Gift Planning in 2021," which was published in the New Jersey Law Journal.

Integrated Asset Protection, Respada
July 29, 2021

Of Counsel Michael Pfeifer served on the panel, "Integrated Asset Protection," a webinar hosted by Respada on July 29.

50 Firms Named 'Best Law Firms For Women'
June 24, 2021

Day Pitney Press Release

Day Pitney Included on Seramount's List of "Best Law Firms for Women"
June 22, 2021

Day Pitney Press Release

With Great Powers (of Appointment) Come Great Responsibility
June 16, 2021

Andrew M. Nerney and Stephanie Eassa Rapp co-authored the article, “With Great Powers (of Appointment) Come Great Responsibility,” published by WealthManagement.com. 

Reuters’ Career Tracker: Lawyers on the Move
June 4, 2021

Scott Brian Clark’s arrival to the firm was featured in Reuters’ column, Career Tracker: Lawyers on the Move.
Related Professionals
Merino, Carl
Carl A. Merino
New York, NY
T: (212) 297 5829
Dina Kapur Sanna
Dina Kapur Sanna
New York, NY
T: (212) 297 2455
Seth Mersky
Seth J. Mersky
Miami, FL
T: (305) 373 4019
New Jersey Hartford Stamford Greenwich New Haven West Hartford Boston
New York Washington, DC Providence Boca Raton Delray Beach Miami West Palm Beach

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