Tag Archives: International Tax

International Tax Breakfast Series: The Impact of U.S. Tax Reform on Inbound and Outbound Planning

Join us April 26th for the next edition of Bilzin Sumberg’s International Tax Breakfast Series. Tax and Private Wealth Services attorneys Hal J. Webb and Jennifer J. Wioncek will explore the Tax Cuts and Jobs Act legislation and its impact on inbound and outbound U.S. income tax planning for international private clients. Topics of discussion include: Changes impacting individual and family … Continue Reading

How Will TCJA Affect Individuals Electing Corporate Taxation?

by Andrew Velarde, Tax Notes International Magazine The Tax Cuts and Jobs Act (P.L. 115-97) has brought newfound attention to an election by individuals to treat themselves as corporations, as well as important questions about uncertainties surrounding its interplay with newly enacted international provisions. Section 962 was drafted in 1962 and until recently was largely … Continue Reading

The (Unintended?) Consequences of Tax Reform on Inbound Financing Structures

Most of the attention surrounding the international aspects of Public Law No. 115-97, formerly known as the Tax Cuts and Jobs Act (the “Tax Reform Act”), has understandably focused on outbound provisions, including Section 951A (GILTI), Section 250 (FDII), Section 965 (deemed repatriation tax), and Section 245A (dividends received deduction).[1]  The scope of the implications … Continue Reading

Reduction in U.S. Corporate Tax Rates Will Significantly Impact Outbound Tax Planning by U.S. Individuals

The Tax Cuts and Jobs Act (“TCJA”) represents the most significant tax reform package enacted since 1986. Included in this reform are a number of crucial changes to existing international tax provisions.  While many of these international changes relate directly to U.S. corporations doing business outside the United States, they nevertheless will have a substantial … Continue Reading

International Tax & Wealth Planning Conference

Bilzin Sumberg’s International Tax Practice is hosting its Annual International Tax & Wealth Planning Conference November 2nd – 3rd in Miami, Florida. This conference will highlight the latest developments in the ever changing international tax and wealth planning environment and will cover current topics such as the impact of the new multilateral tax treaty, the … Continue Reading

The Malta Pension Plan – A Supercharged, Cross-Border Roth IRA

Relevant US Tax Principles In the cross border setting, two of the principal goals in international tax planning are (i) deferral of income earned offshore and (ii) the tax efficient repatriation of foreign profits at low or zero tax rates in the United States. For U.S. taxpayers investing through foreign corporations, planning around the controlled … Continue Reading

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

International Tax Breakfast Series: Recharacterizing Debt as Equity

The next installment of our International Tax Breakfast Series looks at an area of tax law where the exact application of a proposed rule remains uncertain. Please join us for “Recharacterizing Debt as Equity: How the Proposed Section 385 Regulations Will Impact Traditional Cross-Border Income and Estate Tax Planning.” The breakfast event will be held … Continue Reading

International Tax Breakfast Series: International Tax Planning for Artists, Entertainers & Athletes

Please join us for the next installment of our International Tax Breakfast Series, International Tax Planning for Artists, Entertainers & Athletes, which will be held at our offices next Wednesday, June 1st, from 8:30 a.m. to 10:00 a.m. Do you have clients who are artists, athletes, or entertainers? Would you like to add value to … Continue Reading

Change in the UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty.  After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view that the tie-breaker clause will … 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

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology country in Europe and one … 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

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish” and “Double Irish Dutch Sandwich” … Continue Reading

IRS Denies Treaty Benefits Despite Lack of Treaty Shopping

In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from the IRS of approximately $38 million.  The refund is allegedly due to an overpayment of U.S. withholding taxes on dividends … Continue Reading

“Return of Basis” Repatriation Strategy Tested in Tax Court

U.S. multinationals literally have trillions of dollars of untaxed earnings purportedly “trapped” offshore because of the associated high U.S. corporate income taxes that would be incurred if these earnings were repatriated to the United States. While a number of strategies have been marketed to, and used by, U.S. multinationals in an attempt to repatriate these … Continue Reading

IRS Taking Closer Look at Section 956 Inclusions

Each “U.S. Shareholder” of a controlled foreign corporation (“CFC”) is required to include in their gross income as a deemed distribution their pro rata share of the amount determined under section 956 for that year (i.e., “Section 956 inclusion”). A Section 956 inclusion is generally equal to the lesser of (i) the amount of “U.S. … 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

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation).  The deal is expected to close in 2014 or 2015. The agreement values … Continue Reading
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