One Note Samba
La legislación fiscal de EE. UU., promulgada el 4 de julio, amplía las obligaciones de reporte para fideicomisos extranjeros y entidades con traspaso de ingresos, al tiempo que consolida disposiciones clave de la reforma de...more
The July 4 U.S. tax legislation expands reporting obligations for foreign trusts and pass-through entities while locking in key provisions from the 2017 reform. For attorneys and advisors to high-net-worth individuals, this...more
High-net-worth individuals and families contemplating diversifying their wealth beyond U.S. borders, also known as outbound wealth planning, may be motivated by concerns about domestic political developments, economic policy...more
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
Welcome to “Lost in Translation: Blunders in International Estate Planning.” This blog series explores the rarified world of international estate planning, uncovering potential pitfalls and providing insights to navigate the...more
Unlike most countries in the world, if you are a citizen or resident of the United States, the government gets to tax all of your worldwide income, regardless of where it's earned or where you live. And if the IRS decides...more
Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...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
The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more