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US Tax Law
Olivier Thevoz, Tax Attorney in New York
Gift Tax Implications for U.S. Citizen Spouses Giving to Non-U.S. Citizen Spouses
U.S. citizens gifting to non-U.S. citizen spouses face limits: no unlimited marital deduction, and only $190,000 (2025) excluded annually. Gifts above require Form 709. Proper planning helps avoid gif... ...more
US Tax
October 26, 2025•1 min read
𝐄𝐬𝐭𝐚𝐭𝐞 𝐨𝐟 𝐑𝐨𝐰𝐥𝐚𝐧𝐝 𝐯. 𝐂𝐨𝐦𝐦𝐢𝐬𝐬𝐢𝐨𝐧𝐞𝐫, 𝐓.𝐂. 𝐌𝐞𝐦𝐨 𝟐𝟎𝟐𝟓-𝟕𝟔
The Rowland case underscores strict compliance for DSUE portability elections—timely, complete Form 706 filings are essential; safe harbor and equitable relief can’t cure late or incomplete submission... ...more
US Tax
October 26, 2025•2 min read
SEC v. Jarkesy – Potential Ripple Effects in U.S. Tax Enforcement
The 2024 SEC v. Jarkesy ruling grants a jury trial right for civil fraud penalties, reshaping U.S. tax enforcement. It may shift IRS strategies, increase jury trials, and add complexity to tax litigat... ...more
US Tax ,Litigation
October 13, 2025•1 min read
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