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
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
1/4/2024
/ Chile ,
Dividends ,
Income Taxes ,
Interest Income ,
International Tax Issues ,
Investment ,
IRS ,
Royalties ,
Tax Liability ,
Tax Planning ,
Tax Treaty ,
U.S. Treasury ,
Withholding Tax
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
11/14/2023
/ Capital Gains ,
Estate Tax ,
Exclusions ,
Expatriates ,
Gift Tax ,
Inflation Adjustments ,
Internal Revenue Code (IRC) ,
IRS ,
Reporting Requirements ,
Tax Liability ,
Tax Planning
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
In a previous post, we provided an overview for determining a person's U.S. income tax residency status under the substantial presence test (the "SPT"), a test which relies on a mathematical formula for computing an...more
What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more
The IRS recently issued general legal guidance illustrating the application of the often misunderstood relevance rules for foreign entities in various settings....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
With the holiday season upon us, we thought it would be a good idea to review some of the gift tax rules uniquely applicable to foreign clients. This post examines the rules surrounding one type of gift in particular – the...more
The IRS recently released its annual Revenue Procedure containing inflation-adjustments for 2021. Of interest to international tax and estate planning practitioners are the following...more
Ever since the advent of FATCA and related global tax transparency movements, U.S. individuals living abroad have likely become far too acquainted with the challenges posed by holding U.S. citizenship or residency. Perhaps...more
On September 21, 2020, the IRS finalized (with certain modifications) proposed regulations that had been issued last year regarding some of the unintended consequences of the downward attribution rules under Section 958(b)....more
On August 28, the IRS announced that it would temporarily accept e-signatures on certain forms. Included among that initial list of forms was Form 8832, Entity Classification Election (commonly known as a “check-the-box”...more
On April 21, 2020, the U.S. Treasury Department and the Internal Revenue Service released three forms of guidance directed at non-U.S. individuals and non-U.S. businesses affected by travel disruptions arising from the...more