Tag Archives: Outbound Investment

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

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
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