What Type of Book Is That?

Back in April we gave you some trivia about the longest word in the English language that can be made using the letters on only a single row of the standard English alphabet keyboard: “Typewriter.”
Now tell us the first novel that was ever written on a typewriter?

What’s a Burgee?

The only State in the United States that does not have a rectangular flag is the State of Ohio. Although some refer to it as a triangle, it’s actually a burgee, the name for a swallow-tailed flag.

Bill Murray

“It’s hard to win an argument with a smart person, but it’s damn near impossible to win an argument with a stupid person.”

Missing Children, Genetics & the Law

As I mentioned in my Legal Bytes post a few weeks ago (Forensic DNA and Missing Children: The Legal & Ethical Issues), I had the honor and privilege of being a featured speaker on 25th of May 2017 – International Missing Children’s Day – at this year’s conference for Missing Children and Genetic Identity, organized and chaired by Patrícia Cipriano, President of the Portuguese Association for Missing and Exploited Children [Associaçāo Portuguesa de Crianças Desaparecidas] held at Lusófona University in Lisbon.

Featuring expert investigators, law enforcement, geneticists and forensic scientists, the conference explored how tough police work, forensic science, government legislators, judges and lawyers can work more effectively and cooperatively within and across national borders.  It also reminded us that DNA kits and learning aides for use by parents, coupled with greater educational efforts and more timely reporting, can help save children’s lives and futures.

The conference was attended by notable dignitaries, including Charlie Hedges, Police Expert, Missing Children and European Alert Coordinator for Amber Alert Europe, Professor Maria do Carmo Fonseca, President of the Institute of Molecular Medicine, Professor Maria do Ceu Machado, President of Infarmed, members of Portuguese Assembly of the Republic , senior law enforcement and forensic scientists with closing remarks delivered by His Excellency Dr. Fernando Negrão, a jurist and former Minister of Social Security, Family and Children, Minister of Justice, director general of the Judicial Police and chairman of the Board of Directors of the Institute of Drugs and Drug Addiction.

The conference highlighted the work being done in Portugal and, of course, the work that still needs to be done.  You can read and download the Conference Agenda & Brochure (Lisbon, PT) and feel free to take a look at my presentation Missing Children – Missing Opportunities, Legal Obstacles in our DNA (Rosenbaum) right here on Legal Bytes.

As always, f you would like to know more about this post, the conference, or the topics discussed at the conference, feel free to contact me, Joe Rosenbaum.



Flying the Flag

What is the only State flag in the United States that is not a rectangle?

Moonlighting as La La Land!

The real name of the awards given out by the Academy of Motion Picture Arts & Sciences each year is The Academy Award of Merit.

Harry S. Truman

“It is amazing what you can accomplish if you do not care who gets the credit.”

US Treasury Regulation Changes Could Impact Foreign Owned Single Member LLCs

Melinda Fellner Bramwit, Partner, Rimon, P.C.

Changes to US Treasury Regulations Under Section 6038 of the Internal Revenue Code could affect filings for single member LLCs owned by non-US individuals or entities.

Many non-resident individuals and non-resident entities maintain title to real estate and other assets in single member limited liability companies incorporated under state law in the United States, for a variety of reasons.  Under Federal tax law, such an entity is disregarded for tax purposes unless the owner elects otherwise.  From a corporate perspective, these limited liability companies can be used to harness assets in an entity separate from the owner, providing a layer of corporate protection and perhaps anonymity for the ultimate owner.  These entities are also reasonably simple to form and maintain.

Changes to U.S. Treasury Regulations effective December 13, 2016, throw a wrinkle into the use of this malleable entity in some circumstances, which can be managed with some planning.

These changes require that a non-resident owning 100% of a United States limited liability company (“LLC”) file a Form 5472, an information return, when certain transactions occur between certain parties (“related” parties) and the LLC.

The following example from the regulations illustrates a scenario where this filing would be triggered:

In year 1, F, a foreign corporation forms and contributes assets to US-LLC, a U.S. limited liability company that is a disregarded entity for US Federal tax purposes.  In year 2, F contributes funds to US-LLC, and in year 3, US-LLC makes a payment to F.

Under the modified regulations, F’s payment to US-LLC as well as US-LLC’s payment back to F are both reportable transactions for which a Form 5472 would be required with respect to US-LLC.

This is a simple, yet common situation which triggers the filing requirement. It is important to note that this requirement is applicable to tax years of entities beginning on or after January 1, 2017 and ending on or after December 13, 2017 (Note: This is not a typo. The date is the 13th, not the 31st).  As such, there is a window of opportunity for tax planning to avoid the requirement of this form and if you want to know more or need help, don’t hesitate to contact me, Melinda Fellner Bramwit, a partner here at Rimon, P.C.

Of course, if you need assistance, you may always contact me, Joe Rosenbaum, or any of the lawyers with whom you routinely work at Rimon Law.

. . . and the Oscar Goes To

What is the actual name of the honor and award referred to as the “Oscar” given out by the Academy of Motion Picture Arts & Sciences?

Traveling Down the Highway on Wings

Listed below, in answer to this past UBCF trivia question are the members of each band (and for Wings, some of their past members as well) for your reminiscing pleasure.

Wings: Paul McCartney (Beatles), Linda McCartney, Denny Laine (The Moody Blues), Henry McCullough (Spooky Tooth) and Jimmy McCulloch (Stone the Crows). Past members included Denny Seiwell, Geoff Britton, Joe English, Steve Holley and Laurence Juber. The group also used the names Suzy and the Red Stripes and The Country Hams during their run (pardon the pun).

The Highwaymen: Johnny Cash, Waylon Jennings, Willie Nelson and Kris Kristofferson.

Traveling Wilburys: Roy Orbison (who died shortly after the first album was released), Tom Petty (Tom Petty and the Heartbreakers), George Harrison (Beatles), Bob Dylan and Jeff Lynne (Electric Light Orchestra).

To give you some extra food for musical thought, consider all the bands Eric Clapton has played with or been associated with during his career: The Yardbirds, John Mayall & the Bluesbreakers, Cream, Plastic Ono Band, George Harrison, Blind Faith, Delaney & Bonnie and Friends, Derek and the Dominos, J. J. Cale and B.B. King.