In most cases it is advisable to have a Jersey Will to cover investments held in Jersey, as this allows personal representatives to gather and realise or distribute assets more quickly. While a fast-track process can...more
An emerging issue affecting tariff refund claims under the IEEPA Phase 1 Declaration process submitted through the CAPE system may require immediate action by non-resident importers to avoid delayed or rejected refund...more
In brief- If the changes in the exposure draft are enacted: • New ATO notification requirement: Vendors will need to notify the ATO when issuing a CGT membership declaration in transactions valued at $50M or more, a...more
New York City Mayor Zohran Mamdani and New York State Governor Kathy Hochul have announced a proposed Pied-à-Terre Tax which would levy an annual surcharge on one to three family homes, condominium and cooperative properties...more
In our previous article , we examined the 19 December 2025 Ruling of the Italian Revenue Agency, which allowed the concurrent application of (i) the Inbound Workers Regime (“IW Regime”) on Italian-source...more
The 2024-25 Federal Budget contained a somewhat vague (but relatively modest) announcement of a ‘clarification and broadening’ of the classes of assets in respect of which non-residents would be subject to Australian capital...more
New York has once again missed its April 1 budget deadline, in no small part because the Governor’s party, which controls both the State Senate and Assembly, is once again at odds with the Governor over tax policy. The...more
The market for private equity limited partner (“LP”) secondary transfers continues to grow. In order for buyers and sellers of secondary interests to assess the economics of the deal and potential risks to execution, both...more
The Washington state legislature has adjourned for 2026, and key tax changes are in store if Governor Bob Ferguson signs several tax-related bills into law, and if those tax changes then survive expected legal challenges. The...more
Earlier this month, the U.S. Small Business Administration (SBA) banned foreign nationals, non‑citizens, and lawful permanent residents whose principal residence was outside of the U.S. from owning any interest in a small...more
On March 9, 2026, Senator Bill Cassidy and Congressman Jodey Arrington introduced a bicameral bill known at the Securing Accountability in Foreign Entries Act (“SAFE Act”). The SAFE Act would amend the Tariff Act of 1930 to...more
Ohio Governor Mike DeWine signed the E-Verify Workforce Integrity Act into law, creating new compliance obligations for nonresidential construction contractors in Ohio....more
Private clients investing in US-situs assets, such as interests in US real property or stock of a US corporation, take particular care to ensure that their investments are structured in a tax-efficient manner. For many...more
Ohio has adopted a new workforce verification law that will directly affect many construction companies operating in the state. Beginning March 19, 2026, certain construction employers will be required to use the federal...more
On December 18th, Kilpatrick tax partner Jeff Reed presented during a webinar hosted by Strafford/Barbri. The webinar discussed recent state tax developments in the Northeast....more
The government has announced the creation of new separate rates of income tax for property income, including a new property basic rate of 22%, with effect from April 2027. This represents an increase from the current basic...more
It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more
As of November 1st, transferors of real estate located in Massachusetts will have to comply with new regulations (830 CMR 62B.2.4) that may require tax withholding at closing. ...more
In a nearly unanimous decision, the Pennsylvania Supreme Court held that the City of Pittsburgh’s (City) 3% tax on income earned by City nonresidents while performing at one of its publicly funded sports stadiums, the...more
Effective November 1, 2025, non-resident sellers (or transferors) of Massachusetts real estate with a gross sales price of $1,000,000 or more may be subject to withholding at a default rate of 4% or more on the gross sales...more
The Pennsylvania Supreme Court has affirmed the Commonwealth Court and ruled that Pittsburgh’s Non-Resident Sports Facility Usage Fee (“Facility Fee”) unconstitutionally discriminates against nonresidents in violation of...more
The U.S. estate tax is a transfer tax on the value of property transferred at death. The tax applies differently depending on whether a person is considered a U.S. person or a non-U.S. person at the time of the transfer. For...more
On October 1, 2025, Governor Gavin Newsom signed into law AB 1503, creating wide-ranging changes for the world of pharmacy inside and outside California. The new legislation affects pharmacy operations, nonresident pharmacy...more
L’article 155 B du Code général des impôts (CGI) prévoit que l’exonération attachée au régime des impatriés bénéficie aux salariés et dirigeants appelés de l’étranger pour occuper, pendant une durée limitée, un emploi au sein...more
Many Massachusetts residents have recently considered taking, or have undertaken, steps to relocate from Massachusetts to jurisdictions with lower or no state income taxes, especially in light of the recently enacted 2023...more