News & Analysis as of

Foreign Trusts

Citizenship of Aircraft Owner Trustee Establishes Federal Court Diversity Jurisdiction

by Holland & Knight LLP on

The Southern District of New York has confirmed that when the trustee of a non-citizen aircraft trust brings suit in its own name, the citizenship of that trustee may be used to establish diversity jurisdiction in federal...more

Budget 2017

by Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax...more

Non-Dom Reforms Update – United Kingdom

by McDermott Will & Emery on

Summary - Following the United Kingdom’s vote to leave the European Union on 23 June, and the change of Prime Minister and to the UK Government, there was significant uncertainty regarding what would happen to the...more

Will the Panama Papers Lead to Criminal Charges Against U.S. Taxpayers?

by Perkins Coie on

The International Consortium of Investigative Journalists (ICIJ), collaborating with German newspaper Süddeutsche Zeitung, in spring 2016 began leaking approximately 11 million internal documents obtained without permission...more

Group Seeks Relief For U.S. Citizens With RESP and TFSA Accounts

by Hodgson Russ LLP on

In a letter dated March 4, 2016, the American Chamber of Commerce in Canada (“AmCham Canada”) requested that the United States Department of the Treasury (“Treasury”) provide various forms of tax relief to U.S. and Canadian...more

Congress Sneaks in Some Important Procedural Tax Changes

by Charles (Chuck) Rubin on

On July 31, 2015, President Obama signed HR 3236, the "Surface Transportation and Veterans Health Care Choice Improvement Act of 2015." While you wouldn’t know it from the title, Congress included some important procedural...more

Premarital planning - Protecting your assets without a prenup

Protecting family assets in the event of a divorce is particularly significant for family business owners, who typically want to avoid sharing ownership with their ex-spouses or their children’s ex-spouses. A prenuptial...more

Cross-Border Activities: Benefits of Filing “Protective” Returns

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

I Want to Live in America!- Part I Tax Planning Considerations for Foreign Scientists and Engineers

by Gerald Nowotny on

Overview - As discussions regarding immigration reform continue to unfold, one point that is not under discussion or subject to debate is the contribution of foreign scientists and engineers to the New Economy. The statistics...more

Non-FBAR Penalites and Offshore Voluntary Disclosures

by Sanford Millar on

The following summarizes in explicit detail why taxpayers who have an unfilled Report of Foreign Financial or Bank Account (FBAR) must consider entering the Offshore Voluntary Disclosure Program (OVDP). Not only does the...more

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