Categories

Author

Year

Publications

3/2021

Reporting Beneficial Owners of Certain US Companies: Details of the New Corporate Transparency Act

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.…

2/2021

Piercing the Veil: Do New U.S. Transparency Rules Make the Cut?
Tax Notes Article

Severiano Ortiz is quoted in an article discussing the Corporate Transparency Act. Tax Notes. February 9, 2021. Download…

1/2021

The Future of Trusts – Threats, Challenges, and Solutions
Cayman Islands, Society of Trust & Estate Practitioners

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…

12/2020

Special Residency & Citizenship Programs: Austria | Bahamas | Ireland | Italy | Portugal | Spain | UK
Society of Trust & Estate Practitioners, Webinar

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…

9/2020

UK-US Tax Planning: Trusts, Residential Real Estate, and Real Estate Investment Planning
Society of Trust & Estate Practitioners, Webinar

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…

US Individuals Investing in Foreign Companies Should Consider a Section 962 Election to Reduce the GILTI Tax Burden

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…

5/2020

Impact of the COVID-19 Pandemic on Tax Residence Rules

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…

4/2020

Small Business Loan Warning Doesn’t Get to Heart of the Issue: Payment Protection Program (PPP)
Tax Notes Article

Severiano Ortiz is quoted in an article discussing potential issues related to the Payment Protection Program (PPP). Tax Notes. April 24, 2020. Download…

12/2019

Identifying Business and Investment Trusts

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…

10/2019

U.S. Tax Implications of Offshore Trusts

Present lecture on assessing trust structures from a U.S. income tax perspective. RSM US LLP – Internal Private Client Training. October 1, 2019.…