AI Today in 5: August 12, 2025, The Creating Billionaires Episode
AI Today in 5: August 11, 2025, The ACHILLES Project Episode
Taxing Intelligence: AI's Role in Modern Tax Administration
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
Taking the Pulse, A Health Care and Life Sciences Video Podcast | Episode 242: Business Planning in Healthcare & Life Sciences with Jennifer McEwen of Maynard Nexsen
PODCAST: Williams Mullen's Benefits Companion - Employee Stock Ownership Plans (ESOPs) Explained
GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Impuesto de Timbre: Cuantía indeterminada
Essential Steps to Sell Your Business
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
Insights on Planned Giving From the BNY Annual Charitable Giving Report for 2024
Investing Charity and Foundation Assets in Turbulent Times With Jennifer Nelson
Podcast - Colaborar por contrato... sí funciona
Charitable Split Interest Trust Planning with Dale Schroeder and Anneke Niemira, Part Two
Charitable Split-Interest Trust Planning With Dale Schroeder and Anneke Niemira - Part One
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Choosing Your LDA Reporting Path for 2025
Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare
Nonprofit Basics: IRS 10-Course Charity Workshop
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. Blunder...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
It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024. US tax authorities are not shaking up the international private client landscape, but instead are providing...more
Explaining a Foreign Trust in Easy-to-Understand Language - In this global economy, it’s becoming increasingly common for U.S. citizens and residents to have financial ties overseas. These financial ties often come in 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
Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more
The Continuing Saga of U.S. Tax Classification of Foreign Trusts and Related Penalty Issues - In Greek mythology, Cerberus, a three-headed dog, was known as the guardian of the underworld. In more recent literature, a...more
In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties. The case arose in the context of a Liechtenstein...more
Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a Form 3520, a Form...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
In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more
In my previous post, I discussed some of the relevant U.S. federal tax implications to consider when a foreign individual makes a gift of cash to a U.S. person. That discussion assumed that the gift was coming directly from...more
On August 28, the IRS announced that it would temporarily accept e-signatures on certain forms. Included among that initial list of forms was Form 8832, Entity Classification Election (commonly known as a “check-the-box”...more
Section 6048 of the Internal Revenue Code requires reporting of a U.S. citizen or resident alien’s (a) transfers to a foreign trust, (b) annual financial information related to the U.S. person’s interest in a foreign trust,...more
Astrid Owen leads this interactive webinar to discuss the US taxation of US beneficiaries and US settlors of non-US trusts. The benefit of using non-US grantor trusts established by a non-US person for US beneficiaries...more
Using U.S. domestic trusts and private placement insurance products to invest in the U.S. ...more
Este artículo relacionará los beneficios del uso de fideicomisos estadounidenses para ciertas inversiones entrantes. Fideicomisos de EE. UU., considerados fideicomisos extranjeros con fines fiscales, es una nota....more
A Foreign Trust can be a legitimate instrument for US Taxpayers that may have family members in foreign jurisdictions, have foreign business interests or are the beneficiaries of trusts created in other countries. ...more
Do you or did you have a wealthy relative from a different country? Did that relative make you a beneficiary of a non-U.S. trust? Lucky you. But beware that free wealth....more