News & Analysis as of

International Tax Issues Tax Planning Trusts

Cadwalader, Wickersham & Taft LLP

What Constitutes a POEM?

In Haworth v HMRC [2025] EWCA Civ 822 (Haworth) the UK Court of Appeal (CoA) provided much needed clarity regarding the approach to determining the ‘place of effective management’ (POEM) in the context of the UK’s double tax...more

Walkers

Channel Islands a strategic hub for employee share incentive plans

Walkers on

In today’s competitive business environment, share incentive plans continue to be a popular tool for aligning employee interests with those of management and shareholders. Guernsey and Jersey, as leading offshore financial...more

McDermott Will & Schulte

IRS Roundup March 15 – March 28, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more

Walkers

The Alphabet Trust and its benefits for South African families

Walkers on

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

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

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

Offit Kurman

Not Knowing the Tax Implications of How Your Client is Classified?

Offit Kurman on

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

Hogan Lovells

How the UK Trust Registration Service applies to trusts of real estate and changes for unit trusts

Hogan Lovells on

Trustees which are UK resident, have UK assets or income which trigger a UK tax liability or directly acquire UK land on or after 6 October 2020 will generally have to register the trust with HMRC's Trust Registration Service...more

McDermott Will & Schulte

[Webinar] International Tax Transparency Update - November 18th, 3:00 pm GMT

McDermott Will & Schulte on

Our International Tax Transparency Update will cover DAC6, the UK’s Trust Registration Service and other global registration requirements that may be relevant for businesses. The importance of these requirements cannot be...more

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