News & Insights
Tax Implications of Exiting a Controlled Foreign Corporation
The income of a foreign corporation is not subject to federal corporate income tax unless the foreign corporation has income that is effectively connected with
Tax Implications of Exiting a Domestic C Corporation
Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best
Why Are the Global Elite Using U.S. Trusts?
Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best
Getting the Tax on Qualified Small Business Stock Correct
With the reduction of the corporate income tax rate from 35 percent to 21 percent and the ability to exclude a significant amount of gain
Clowns of the CRUT (Part 2 of 2)
This is Part 2 of the newsletter on charitable remainder unitrusts (“CRUT”) which is a common planning technique for the charitably inclined high net worth
Clowns of the CRUT (Part 1 of 2)
A charitable remainder unitrust (“CRUT”) is a common planning technique for the charitably inclined high net worth. The CRUT allows for the tax-free liquidation of
New Precedent of Finland Supreme Court – Criminal Penalties for Unreported Foreign Investment Income
On February 27, 2023, the Supreme Court of Finland set a new precedent (KKO:2023:15) in their ruling concerning the application of penalties for tax evasion
Tax Planning for Foreign Investors
With the global economy we live in, it is important for Fund Managers to have an appropriately structured fund if they plan to have foreign
Comprehensive Planning to Provide the Most Tax-Efficient Structure
CFOs and General Counsel of multinational corporations (non-U.S. parent) with operations in the United States face complex tax implications that must be planned for on