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Trusts International Tax Issues

Foodman CPAs & Advisors

Reforma Fiscal de EE. UU. 2025: Cerrando Brechas de Cumplimiento en Fideicomisos Offshore y Estructuras Transfronterizas

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

Foodman CPAs & Advisors

U.S. Tax Reform 2025: Closing Compliance Gaps in Offshore Trusts and Cross-Border Structures

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

Levenfeld Pearlstein, LLC

Establishing Your Financial Presence Outside the United States: A Strategic Guide

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

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

Proskauer Rose LLP

UK Tax Round Up - July 2025

Proskauer Rose LLP on

Welcome to July’s edition of our UK Tax Round Up. Apart from the draft legislation and accompanying material released on 21 July as part of “L-Day” (legislation day), July was a fairly quiet month for UK tax developments....more

Walkers

Channel Islands a strategic hub for employee share incentive plans

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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

Bilzin Sumberg

Do You Know Where Your Gift or Bequest Is Coming From? If Not, You May Be Subject to a Gift/Inheritance Tax and the Related New...

Bilzin Sumberg on

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

Allen Barron, Inc.

Offshore Real Estate Ownership and Tax Reporting Requirements

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What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to...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

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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

Offit Kurman

Forgetting to File International Forms

Offit Kurman on

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

Cadwalader, Wickersham & Taft LLP

A Toothless Tax Avoidance Scheme: M Northwood v HMRC

The UK’s First-tier Tribunal (“FTT”) has denied a taxpayer a deduction for contributions to a remuneration trust on the basis that such payments did not give rise to an expense under generally accepted accounting principles...more

Hogan Lovells

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

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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

Cadwalader, Wickersham & Taft LLP

Haworth: Residency Tie-Breaker Tests in a ‘Round the World’ Tax Scheme

The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...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

Womble Bond Dickinson

Impact Investing: A Growing Trend For Foundations On Both Sides Of The Pond

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The last few years have seen an increasing number of foundations engage in a wide spectrum of impact investing i.e. investing to generate a social return and further their mission or a social purpose, rather than investing to...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Goodwin

IRS Amends Revenue Ruling 81-100 to Permit Participation in Group Trusts by Puerto Rico Plans and Insurance Company Separate...

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The Internal Revenue Service (the “IRS”) issued Revenue Ruling 2014-24 (the “Ruling”). The Ruling amends Revenue Ruling 81-100, the ruling that established the requirements applicable to a tax-qualified group trust. The...more

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