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 ,
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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 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
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
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 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
These are interesting times that we live in, to say the least. The outbreak of the coronavirus has dramatically changed the course of day-to-day life, even if only for a temporary period. Quarantines and travel restrictions...more