Until recently, there was a fair amount of comfort amongst practitioners that, when structured correctly, utilizing a tax reimbursement clause for a grantor trust did not produce any negative U.S. gift or estate tax results....more
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
It didn’t take very long for 2021 to bring about federal legislation that could significantly impact, or at least cause massive administrative headaches for, domestic and international private clients and their holding...more
In my previous post, I discussed some of the relevant U.S. federal tax implications to consider when a foreign individual makes a gift of cash to a U.S. person. That discussion assumed that the gift was coming directly from...more