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Treasury Dept. Identifies 8 "Significant Tax Regulations" for Review to Reduce Burden

by Holland & Knight LLP on

The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...more

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Update on Domicile and Tax of Offshore Trusts

by McDermott Will & Emery on

Implementation of the 6 April 2017 tax changes applicable to non-domiciled individuals, offshore trusts and UK residential property has been delayed because of the forthcoming UK General Election on 8 June 2017. Whilst it is...more

QDOT-ting I's and Crossing T's: Estate Tax Planning for Non-United States Citizen Spouses

by Ward and Smith, P.A. on

Individual and corporate citizens from countries around the world have moved to North Carolina and contributed materially to our state's economic, educational, and cultural growth. Foreign direct investment ("FDI") in North...more

Kyiv Tax Newsletter (Ukrainian)

by Dentons on

On 23 March 2017, the President of Ukraine signed the Law of Ukraine “On Amendments to the Tax Code of Ukraine Concerning the Taxation of Inheritance” (hereinafter – the Law on inheritance tax), which simplifies the...more

Kyiv Tax Newsletter - April 2017

by Dentons on

On 23 March 2017, the President of Ukraine signed the Law of Ukraine “On Amendments to the Tax Code of Ukraine Concerning the Taxation of Inheritance” (hereinafter – the Law on inheritance tax), which simplifies the...more

Reporting Foreign Income: Four Common Misconceptions

by Moskowitz LLP on

The U.S. government has stringent reporting requirements when it comes to foreign assets and income, but many people are still not coming into compliance based on some mistaken beliefs. Here are four common misconceptions...more

When the Wall of Secrecy Collapses

by Foodman CPAs & Advisors on

Foreign Accounts, Shell Companies, Blind Trusts, Asset Protection Trusts, Offshore Trusts, Global Citizenship and US Residency are just a few of the Terms highlighted in the mega divorce proceedings of a Palm Beach County...more

Final Response to Non-Dom Consultation Published - Update

by McDermott Will & Emery on

The UK government has released its final response to the further consultation on reforms to the taxation of non-UK domiciliaries (non-doms), together with draft legislation that will take effect from 6 April 2017. As well as...more

Surcharge tax hits discretionary trusts

by Dentons on

The Office of State Revenue (OSR) has released a ruling on 22 December 2016 in relation to the definition a ‘foreign person’. This is important if you hold an investment property in a discretionary trust....more

Trump Administration's Tax Reform Likely

by Hodgson Russ LLP on

Donald J. Trump defied the polls and much of the national media to win the US presidential election on November 8, 2016. President-elect Trump will be sworn in and will take office as the 45th president of the United States...more

Tax Truths: Volume 1, No. 2 – December 2016

by Ballard Spahr LLP on

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

2016 Year-End Estate Planning Advisory

by Katten Muchin Rosenman LLP on

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Proposed Regs May Limit US Estate Plan

by Hodgson Russ LLP on

On August 2, 2016, the US Treasury issued long-awaited pro- posed regulations under Code section 2704 that make comprehensive and very significant changes to the valuation of interests in many family-controlled entities for...more

[Webinar] U.S. Tax and Estate Planning for Foreign Persons - Meritas Capability Webinar - September 27th - 1:00p.m. U.S. CDT

Many successful people come to the United States from other countries, either permanently or on study or work assignments that are intended to last just for a few years. These people may earn income in the United States and...more

The Hidden Cost Of “Going Home” — the Expatriation Tax for Long-Term Permanent Residents Who Return to Their Home Countries

by Garvey Schubert Barer on

People immigrate to the United States for many different reasons. Many come here for work reasons and, somewhere along the way, obtain permanent resident status, otherwise known as holding a “green card.” They may work in the...more

"FIRPTA Reform Impacts Investment Opportunities in US Real Estate"

In recent months, much has been written to describe the reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) contained in the Protecting Americans From Tax Hikes Act of 2015 (the Act), which have been...more

Foreign Financial Asset Reporting - Coming Soon to a Domestic Entity Near You

by Charles (Chuck) Rubin on

When Form 8938 reporting for foreign financial assets of U.S. taxpayers was first imposed a few years, only U.S. individuals were subject to it. The IRS has now issued final regulations that will commence reporting by...more

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

by Gerald Nowotny on

Overview - If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe...more

Swiss Cheese con Arroz con Pollo – Pondering Offshore Planning after the Panama Papers Scandal

by Gerald Nowotny on

Overview - It is an understatement to say that the state of affairs in the offshore landscape is in flux. The fallout from the recent scandal in Panama remains to be seen. The fall of the rich and famous may end up...more

Plan Ahead to Avoid or Minimize US Estate Tax

If you are not a US resident or a US citizen and are considering buying assets in the US, there are ways to avoid or minimize US estate tax on those assets. ...more

A Death Abroad - Assistance and Issues

by Charles (Chuck) Rubin on

The death of a loved one is obviously a difficult time and process for family and friends. If the decedent dies outside of the U.S., the family and friends have the additional burden of dealing with local law and...more

Annual Estate Planning Newsletter: Part Five

by Blank Rome LLP on

Action Item: This is the fifth installment of our Annual Estate Planning Newsletter, and focuses on foreign matters. We urge you to review this installment to ensure that your 2016 estate and tax planning is in...more

FATCA Update: Treasury Issues Long-Awaited Rules For Foreign Asset Reporting by Domestic Entities

by Blank Rome LLP on

The Treasury Department has finally issued regulations implementing the rules requiring domestic entities to annually disclose their foreign financial assets to the Internal Revenue Service. In 2010, as part of the enactment...more

"Important FIRPTA and REIT Reforms Enacted"

The newly signed Protecting Americans from Tax Hikes Act of 2015 (the Act) includes several reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and the taxation of real estate investment trusts...more

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