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Articles by Nicholas Heuer
This U.S. Law Trust is Foreign!
Skip navigation Recent Recent Featured Causing a trust settled under the law of a U.S. state to be classified as a foreign trust for U.S. federal income tax purposes is easy. It can be equally easy for a foreign trust classification to happen accidentally. While there are ways to cure this accident without U.S. tax consequences, it’s increasingly more common for a client’s facts to present a recipe for this situation to occur as the world grows smaller.
This U.S. Trust Has a Foreign Beneficiary!
Resources With increasing global mobility of high-net-worth individuals and families, it’s becoming more common for a U.S. fiduciary to be the trustee of a trust that’s governed by the laws of a U.S. state and has non-U.S. beneficiaries. Consider a retired, non-U.S. married couple that immigrates to the United States and has children who remain non-U.S. individuals. If that couple sets up a typical core estate plan with a trust and U.S. trustee, on their deaths, there would likely be one or more
PTC Me ASAP: Estate Planning with Private Trust Companies | JD Supra
December 6, 2022 To embed, copy and paste the code into your website or blog: More and more families are turning to private trust companies (PTCs) for their trusts and estates. Are they right for you? What is a private trust company? Private trust companies provide trust and fiduciary services to a single-family group — this is their sole purpose, and they are prohibited from doing business with the public.
PTC Me ASAP: Estate Planning with Private Trust Companies
More and more families are turning to private trust companies (PTCs) for their trusts and estates. Are they right for you? What is a private trust company? Private trust companies provide trust and fiduciary services to a single-family group — this is their sole purpose, and they are prohibited from doing business with the public.
Tax on inbound investment in USA | Lexology
Acquisitions (from the buyer’s perspective) Tax treatment of different acquisitions What are the differences in tax treatment between an acquisition of stock in a company and the acquisition of business assets and liabilities? Taxable acquisitionsStock acquisitions All assets and liabilities of the target as they exist immediately prior to the closing are assumed in the transaction. The acquirer receives a basis in the target stock acquired equal to the purchase price.
Tax on acquisitions in USA | Lexology
Acquisitions (from the buyer’s perspective) Tax treatment of different acquisitions What are the differences in tax treatment between an acquisition of stock in a company and the acquisition of business assets and liabilities? Taxable acquisitionsStock acquisitions All assets and liabilities of the target as they exist immediately prior to the closing are assumed in the transaction. The acquirer receives a basis in the target stock acquired equal to the purchase price.
Tax on Inbound Investment in the USA | Lexology
Use the Lexology Getting The Deal Through tool to compare the answers in this article with those from other jurisdictions. Acquisitions (from the buyer’s perspective) Tax treatment of different acquisitions What are the differences in tax treatment between an acquisition of stock in a company and the acquisition of business assets and liabilities?
Key Takeaways From the BEAT Proposed Regulations | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
IRS to Terminate Offshore Voluntary Disclosure Program | JD Supra
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
Prepare Now for 2018 Reporting of Foreign-Owned U.S. Disregarded Entities
Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Already signed up? Log in here By using the service, you signify your acceptance of JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources.
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