Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory

In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory

One Big Beautiful Revenge Tax: Hits Foreigners From “Unfair Tax” Jurisdictions

The U.S. House of Representatives just passed H.R. 1, the “One Big Beautiful Bill Act” by a narrow margin, with the vote being 215 to 214.  Foreign persons (including foreign governments) considering inbound investments should pay close watch as this develops.  The OBBBA has many tax provisions, but one (Section 112029 of the OBBBA) would … Continue reading One Big Beautiful Revenge Tax: Hits Foreigners From “Unfair Tax” Jurisdictions