Tag Archives: Tax Planning

Inbound and Outbound U.S. Tax Planning – What’s Left After the MLI?

The Multilateral Instrument On June 7, 2017, the formal signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument” or “MLI”) took place.  Sixty-eight jurisdictions have signed the MLI, with another nine jurisdictions signing a letter indicating their intent to sign the MLI.[1] … Continue Reading

International Tax Breakfast Series: The Do’s and Don’ts of Domesticating Trusts to the U.S.

Join us May 18th for another edition of Bilzin Sumberg’s International Tax Breakfast Series. The event will feature a discussion on domesticating trusts to the U.S. with Tax and Private Wealth Services attorneys Hal J. Webb and Jennifer J. Wioncek. The U.S. is now preferred as the situs for the administration of many trusts. Hal and … Continue Reading

Creating Non-Taxed “Previously Taxed Income”: The Ultimate Pre-Immigration Strategy

According to recent statistics, immigrants and their U.S.-born children now number approximately 84.3 million people, or 27% of the overall U.S. population.   The countries from which the largest numbers of these individuals originate include India, China, Mexico, and Canada.  Many of those moving to the United States are wealthy business owners who will continue to … Continue Reading

International Tax Breakfast Series: How the Recent Colombian Tax Changes Impact U.S. – Colombia Tax Planning

Join us on February 7th for a new installment of Bilzin Sumberg’s International Tax Breakfast Series. The discussion will cover the recent Colombian tax changes and how they affect U.S.-Colombia Tax Planning. Colombian tax lawyer Camilo Cortes will provide an overview of the changes, which include Controlled Foreign Corporation (CFC) legislation and the introduction of … Continue Reading

Tax Planning for Investments into Brazil

Join us on Wednesday, October 14th at 12:00pm EST for an in-depth joint presentation by tax attorneys Jeffrey Rubinger of Bilzin Sumberg and Fernando Martins of WFaria Advogados on the cross-border tax considerations for  companies doing business in Brazil. During the first part of the discussion, Jeffrey Rubinger will cover some of the basic U.S. tax planning considerations including … Continue Reading

Proposed U.S. Model Treaty Provisions May Dramatically Alter International Tax Landscape

The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures. On May 20, 2015, the Treasury … Continue Reading

American Bar Association Business Law Section Annual Meeting

On Thursday, September 11, I will be speaking at the inaugural American Bar Association – New Business Law Section Annual Meeting in Chicago, Illinois. The ABA Business Law Section Annual Meeting is being held from September 11-13 and is ideal for professionals that want to experience an all-inclusive business law programming event. The entirety of … Continue Reading

Synthetic Investment in U.S. Real Estate by Foreign Investors

According to recent reports, foreign investment in commercial U.S. real estate exceeded $38.7 billion in 2013 – a 40 percent increase over 2012. Leading the way in 2013 were investors from Canada, China, Australia, Germany, and Singapore. This represents a dramatic increase from the 2009 collapse of the U.S. real estate markets, which caused foreign investments … Continue Reading

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election.  Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box regulations”), certain business entities are permitted to choose their classification for U.S. federal income tax purposes by making a check-the-box election. The Federal tax … Continue Reading

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the shareholders in the form of a dividend.  Moreover, when a foreign corporation is resident in a jurisdiction with which the United States has a … Continue Reading

Tax Planning for the Privatization of the Space Industry

The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon. During 2013, SpaceX (the space exploration company founded by Elon Musk, co-founder of PayPal and Tesla Motors) successfully launched a major communications satellite into orbit for a private satellite operator, and became … Continue Reading

Foreign Investment in the U.S. Through Romania Just Became More Interesting

All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision.  The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining countries that have comprehensive income tax treaties with the United States that do not contain LOB provisions. Romania recently enacted … Continue Reading
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