Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more
One of the most challenging aspects of assisting clients with international tax planning is determining the right entity to use for that client’s situation. Although the Internal Revenue Service (the “IRS”) simplified the...more
As you may be aware, the House Ways and Means Committee recently approved a multitrillion-dollar tax package (the “Proposal”) that has significant tax impact on both individuals and corporations. ...more
9/20/2021
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Biden Administration ,
Budget Reconciliation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
GILTI tax ,
International Tax Issues ,
Legislative Agendas ,
Private Equity ,
Tax Reform ,
Ways and Means Committee
On August 25, 2021, Senate Finance Committee Chair Ron Wyden, D-Ore., and fellow Senate Finance Committee Democrats Sherrod Brown of Ohio and Mark R. Warner of Virginia released draft legislation, and a related summary,...more
9/1/2021
/ Biden Administration ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
Proposed Legislation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Rates ,
Tax Reform