This article discusses the new U.S. Corporate Transparency Act that became law on January 1, 2021. For the first time, certain ‘reporting companies’ (either incorporated in the U.S. or non-U.S.…
Our panel discusses recent global developments flowing from the international push towards regulation and transparency, important decisions of the courts that have contributed to the evolution of trust laws around…
In recent months, there has been a trend of US citizens as well as non-EU citizens seeking legal advice in relation to selected countries special residency or citizenship programs. Our…
Discusses the complexities of UK-US tax planning while considering the application of income, gift, and estate tax regimes on various structures. Topics include: Advising trustees of offshore trusts – with…
Updates and further considerations to the uses of a Section 962 Election in scenarios where U.S. income tax residents invest in, or retain, ownership over their non-U.S. corporations. International Law…
Severiano Ortiz participates in the Tax Residence and Coronavirus Working Group to produce comments on Rev. Proc 2020-20, two FAQs published on the IRS website entitled “Information for Nonresident Aliens…
Severiano Ortiz is quoted in an article discussing potential issues related to the Payment Protection Program (PPP). Tax Notes. April 24, 2020. Download…
Present lecture on how to identify whether a trust is in fact a trust for U.S. tax purposes. Often times we are working with “trusts” that are actually Investment or…