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A B C D E F G H I J K L M N O P Q R S T U V W X Y Z View All

Residence and Domicile Issues for Non-Citizens: Key Considerations

by Mallory Schowe | Apr 3, 2025

When it comes to estate and gift taxation, non-U.S. citizens face unique challenges based on their residence and domicile status. Understanding these concepts is crucial for effective estate planning and tax management. Determining Domicile for Estate and Gift Tax...

Supreme Court Update: Thompson v. United States (No. 23-1095)

by Christine Stackhouse | Mar 28, 2025

William Blake once observed that “a truth that’s told with bad intent, beats all the lies you can invent.” It turns out the Supreme Court agrees, at least for escaping liability under 18 U.S.C. § 1014. In Thompson v. United States (No. 23-1095), a unanimous court held...

Supreme Court Update: Delligatti v. United States (No. 23-825)

by Christine Stackhouse | Mar 28, 2025

Federal law provides a mandatory minimum sentence of five years for a person who uses or carries a firearm during a “crime of violence.” In Delligatti v. United States (No. 23-825), the Supreme Court addressed whether a crime of omission involves the “use” of physical...

Scope of CTA’s Reporting Requirements Narrows; No Reporting for U.S. Companies and U.S. Persons

by Mallory Schowe | Mar 25, 2025

The Financial Crimes Enforcement Network (FinCEN) has adopted an interim final rule that significantly narrows the scope of beneficial ownership information (BOI) filing requirements. The interim final rule (i) removes the requirement for U.S. companies and U.S....

Client Alert: Connecticut Case Determines Domicile of Multi-State Taxpayer

by Mallory Schowe | Mar 20, 2025

Navigating the complexities of estate tax can be challenging, especially when determining the domicile of a taxpayer with residences in multiple states. In the recent Connecticut Superior Court case, Daniels v. Commissioner, the court faced the intricate task of...
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