On July 10, 2023, California Governor Gavin Newsom signed into law S.B. 131, which included a provision targeting the California state income tax treatment of incomplete gift non-grantor trusts ("INGs"). Under the prior law,...more
Private credit appears to be the dominating trend throughout emerging business markets. Businesses seeking to raise capital are finding private investors who, unsurprisingly, are looking to maximize yield, while at the same...more
The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more
3/12/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trump Administration
You know what’s better than earning portfolio interest? Nothing. OK, that may be an overstatement. But for non-U.S. lenders looking to earn a return on their U.S.-based investments, with respect to paying U.S. taxes, that’s...more