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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.
Justin M. Hannan authored the article, "IRS Issues Final Carried Interest Regulations," on the Boston Bar Association's Trusts and Estates Blog.
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.
On February 24, Partner Carl A. Merino spoke on "Reporting by U.S. Person of Foreign Income, Assets and Transactions" at a webinar hosted by STEP Colorado Formation and STEP Chicago.
Day Pitney Press Release
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."
Day Pitney Press Release
Day Pitney Press Release
On March 11, Day Pitney Counsel Jordana G. Schreiber spoke on the "Basics of Estate Planning" for physicians at Massachusetts General Hospital.
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