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Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

IRS Provides More Guidance on “Relevance” and Foreign Entities Making “Check-the-Box Elections”

In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context.  More specifically, the guidance addressed issues...more

What Makes a Trust a "Foreign" Trust?

In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more

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