Taxing Intelligence: AI's Role in Modern Tax Administration
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
Impuesto de Timbre, ¿otra vez?
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
Ley Mbappé
Nonprofit Basics: International Grantmaking Part 3 -Special Rules for Private Foundations
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
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 United States recently passed tax legislation called the One Big Beautiful Bill Act (OBBBA), a follow-up to the 2017 Trump tax cuts. While the bill is American, many Canadian families with cross-border ties, including...more
In this alert, which is part of an eight-part series taking a deeper dive into various portions of the Legislation (International Tax; Opportunity Zone and Tax Credits; Green Energy Credits; Estate Planning and Individual Tax...more
On July 4, President Trump signed into law the One Big Beautiful Bill Act (Bill), which was approved by the Senate and House earlier in the week. The 870 page-bill covers nearly every sector of the American economy, and...more
The One, Big, Beautiful Bill Act, passed on July 4, 2025, introduces many significant changes to U.S. tax law, affecting individual, estate and gift, business, and international tax provisions. For some of these changes, it...more
La Cámara de Representantes de los EE.UU. aprobó hoy, con una votación de 218 a favor y 214 en contra, la versión previamente autorizada por el Senado del proyecto de ley conocido como “One Big Beautiful Bill”. Se espera que...more
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
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
Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more
Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...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
As wealth management evolves, South African high-net-worth individuals ("HNWIs") are increasingly looking for efficient offshore structures to protect and grow their assets. One such option is "The Alphabet Trust" -...more
Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in...more
Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups....more
Non-Americans who undertake estate and trust planning for their American citizen or resident family members should be aware of the unique tax issues that face Americans and consider these issues when doing their planning....more
Estate planning tends to be a topic that overwhelms most people. It can be further complicated for modern-day global families whose lives include international nuances. For example, when one spouse is not a U.S. citizen,...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
Please join us on January 29th as we discuss the following topics on estate and gift tax planning for clients with international ties: - Gifting to a non-citizen spouse - The difference between U.S. “residency” for...more
The Tax Cuts and Jobs Act, providing extraordinary estate planning opportunities, was signed into law by the President on December 22, 2017. The new Act allows for a great opportunity to take advantage of increased...more
If enacted, the Tax Cuts and Jobs Act could open up significant estate planning opportunities. The House bill doubles the exemptions from estate, gift and generation-skipping transfer taxes, creating new opportunities for...more