2005 Articles

IRS: Abusive USRPI Transactions: Dec-01-2005 — In its continuing quest to stop tax abuse, the IRS recently outlined two types of US real property transactions involving foreign (non-US) persons that the IRS views as abusive transactions designed to circumvent the US withholding tax.
US-Mexico: Transparencies: Nov-01-2005 — The United States and Mexico have agreed on when treaty benefits extend to a fiscally transparent entity formed under the laws of either country.
Cross-Border Income Securities: Oct-01-2005 — Income trusts have become popular with US companies that make Canadian public offerings. New variations may be more attractive to Canadian investors.
Professional Compensation Is a Gamble in Chapter 11: Aug-11-2005 — This article by Hodgson Russ partner Garry M. Graber was originally published in The Journal of Corporate Renewal, April 2005. Reprinted with permission.
Cross-Border Estate Planning Basics: Jul-25-2005 — Canadian residents who acquire property located or deemed to be located in the United States are subject to potential U.S. estate tax on the value of that property owned at death.
IRS issues new regulations for partnership withholdings: Jul-14-2005 — This article by Hodgson Russ associate Marla Waiss was originally published in The Buffalo Law Journal, vol. 77, no. 56, July 14, 2005. Reprinted with permission.
Some thoughts about costs in international arbitration: Jul-08-2005 — Reprinted with permission from International Arbitration News, Summer 2003
Second Circuit Update: Jun-06-2005 — A brief review of recent notable decisions from the Second Circuit, including cases involving arbitration, electronic privacy, securities litigation, and trademark and copyright infringement.
Proposed rules permit tax-free cross-border mergers: Mar-24-2005 — The IRS recently issued proposed regulations allowing certain mergers and consolidations effective under foreign law to qualify as tax-free A reorganizations.
US Expatriates: Mar-02-2005 — The Jobs Creation Act of 2004, signed into law on October 22, 2004, substantially altered the expatriation tax rules (Code section 877) applicable to US citizens and long-term permanent residents who commit an expatriating act after June 3, 2004.

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