This panel focuses on provisions of the US tax code relevant to assessing and implementing cross-border estate planning. Points of discussion include identifying the tax status of the taxpayer and…
This panel focuses on the application of the US tax laws as they relate to identifying foreign versus domestic trust structures. This panel outlines a roadmap from which to analyze…
Present lecture on Identifying foreign trusts and how to tell the difference between a U.S. domestic versus a foreign trust, and how to identify whether such trust is a grantor…
Our presentation covers the basics of cross-border estate/gift/income tax planning with a focus on identifying tax residency and domicile, domestic versus foreign trusts, international information compliance, and delinquent filing procedures.…
Tax Benefits, Tax Reform, and Fractional Boat Memberships: This article addresses the intersection of the U.S. tax code as applied to houses, boats, and now fractional boat memberships. These days…
Conduct an internal training for our private client department to teach its tax professionals about the application of the U.S. Income Tax Code and related international informational filings. RSM US…
The passage of the 2017 Tax Cuts and Jobs Act (TCJA) was heralded as the beginning of a new age in international taxation. Finally, the injustice of the double tax…
Conduct an internal training for our private client department to teach its tax professionals about the application of the U.S. Estate and Gift Tax Code to non-resident aliens and cross-border…
This presentation discusses the Final Section 956 Regulations, including, the changes from the September Proposed Regulations and the application of the rules to partnerships. PwC US – International Tax Services…
This presentation discusses the basics of a controlled foreign corporation and the complications of de-controlling it with respect to Proposed Regulation 385, local country constraints, and the impact of section…
