Steven Hadjilogiou
Subscribe to Steven Hadjilogiou's PostsSteven Hadjilogiou focuses his practice on tax optimization of business operations and investments with a specific emphasis in the areas of international tax and real estate. Steven provides advice on international inbound and outbound tax planning for multinational companies, family offices, private equity and ultra-high net worth individuals. He also advises funds, family offices and ultra-high net worth individuals in connection with complex real estate structuring and investment issues, including in the areas of opportunity zone funds, 1031 transactions and qualified small business stock. Read Steven Hadjilogiou's full bio.
Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty
By Steven Hadjilogiou and Le Chen on Oct 26, 2023
Posted In Court Procedure Matters, Tax Reform, Tax Refunds, Trial Courts
In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the taxes they pay in their local country can be used as a tax credit to offset the NIIT....
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IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters
By Daniel J. Bell, Steven Hadjilogiou, Kevin Spencer and Evan Walters on Jul 25, 2023
Posted In Uncategorized
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011. These transactions were marketed to many US taxpayers as a way to cash in on their earnings without being subject to US federal taxation....
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Tax Court Tells IRS It Cannot Assess or Collect Certain Tax Penalties
By Daniel J. Bell, Steven Hadjilogiou, Sarah M. Raben and Kevin Spencer on Apr 26, 2023
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds, Trial Courts
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code) Section 6038(b) and collect said penalties via a levy against the taxpayer. The decision in Farhy is significant because the IRS regularly...
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Tax Court Rules That the IRS Cannot Assess or Collect Certain Tax Penalties
By Kevin Spencer, Daniel J. Bell and Steven Hadjilogiou on Apr 5, 2023
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds, Trial Courts
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon Farhy nor collect those penalties via a levy. This is a significant development because the IRS automatically assesses these penalties on any late-filed Form...
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