Author Archives: Seth Buchwald

Seth Buchwald
Seth Buchwald is an associate in the Federal & International Tax Group. He uses his experience as a former certified public accountant (CPA) to understand and assist clients with their complex domestic and international tax planning and structuring issues.  Read More

From Obscurity to Spotlight: The Section 962 Election

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In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits. The rise in popularity of the Section 962 election Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more

Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners

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The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform. How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income The proposed regulations’ complex formula for deemed partnership asset sales Application to tiered partnerships and treaties Read the full advisory here. [...]Read more