Heather Ripley, an associate in the New York office, is a member of the firm's Federal & International Tax Group. Her practice includes federal and international tax planning and controversy, as well as state and local tax issues. She is a member of the New York State Bar Association and is admitted to practice in New York.
Ms. Ripley received her J.D. in 2009 from Harvard University, where she served on the Board of Student Advisers. She received her B.B.A. in accounting, summa cum laude, and her M.Acc. in taxation from the University of Georgia in 2006.
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This advisory discusses how in Chief Counsel Advice (CCA) 201321018, the IRS concluded that a U.S. target corporation’s Section 361(c) distribution of stock of a foreign corporation pursuant to a reorganization constituted an indirect disposition of intangible property, requiring the target to recognize income under the “Disposition Rule” of Section 367(d).
June 17, 2013
Advisories
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This advisory discusses the U.S., Australian and UK tax authorities’ plan to share tax information regarding numerous trusts and other entities holding assets on behalf of residents throughout the world. The three countries have obtained a substantial amount of data, including information about the identities of individual owners and the advisors who helped them establish the structures. The announcement comes amid a flurry of anti-evasion activity spawned in large part by the Foreign Account Tax Compliance Act (FATCA).
The advisory also discusses how the IRS Offshore Voluntary Disclosure Program is not a guaranteed pass for taxpayers; relatedly, it also discusses how the practice of “quiet disclosures continues.
May 15, 2013
Advisories
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This month’s advisory discusses recent IRS regulations on outbound asset transfers; a recent case where the Tax Court held that a nonresident professional athlete’s income from an endorsement deal should be allocated between personal services income and royalties for use of the taxpayer’s “image rights,” based on the facts and circumstances; and a number of President Obama’s 2014 budget proposals that would reform U.S. international tax provisions.
April 15, 2013
Advisories
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In July of this year, Treasury released a model intergovernmental agreement (IGA) that offered a work-around to foreign entities whose countries of residence have laws preventing the entities from complying directly with FATCA and reflected a cooperative intergovernmental approach to tackling international tax evasion. Under the reciprocal and nonreciprocal versions of the model IGA (“Model I”), in exchange for FATCA reporting to the local foreign government (with subsequent automatic exchange with the United States) and certain other reporting of payments made to nonparticipating foreign financial institutions (FFIs), an FFI would be relieved of certain requirements, such as entering an FFI agreement with the IRS, having tax withheld on payments to the FFI, withholding on payments to nonparticipating FFIs (unless the FFI acts as a Qualified Intermediary), withholding on or closing accounts of “recalcitrant” account holders and withholding on pass-thru payments or gross proceeds.
October 15, 2012
Advisories
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August 2012
Publications