Articles & Video
Complex offshore structures – traps and pitfalls: a practical guide
There has been a growing trend over recent years for the development of bespoke and complex holding structures to accommodate the needs and sensitivities of ultra-high net worth individuals. Often, the clients originate from civil law jurisdictions and as a consequence are unfamiliar with trusts and the fiduciary relationship created. There is (understandably) suspicion.
I can see clearly now…
In recent years, there has been a positive deluge of reporting initiatives affecting UK individuals, entities and structures with a UK connection. Some of these have come from the USA (so-called “FATCA”), some from the OECD (the Common Reporting Standard), others from the EU (as a result of the 4th Anti Money Laundering Directive) and others are simply ground-breaking initiatives by the UK government.
Are You An Owner Of A US Disregarded Entity? If So, New Reporting Potentially Now Applies
A reminder from Frank Hirth that the IRS now require the annual filing of Form 5472 in respect of disregarded U.S. entities (such as US LLC's) which are wholly-owned by foreign persons.
Donald Trump & The International Tax Payer: What Can we Expect?
For many the election of Donald Trump as president was a huge surprise, but perhaps less remarked upon and yet not any less of a surprise was the Republican party’s ability to capture control of both houses of congress. Although President Trump can propose and veto legislation, ultimately it is congress which decides on the detail of legislation, and it is likely that it will be the ability of Republicans to control congress which may have the largest long term impact.
US citizens living abroad still face US tax and reporting obligations
Particularly since the US presidential election, some US citizens have moved abroad and others are considering such a move. Tax professionals and trust officers worldwide are fielding questions from these individuals. How to advise them depends on the particular individual's objectives
FATCA - Where are we now?
Given various unexpected results over the last 18 months (general election, following Brexit and trump as surprise votes), I have abandoned any attempts to predict what the future may hold.
This equally applies to the future of the Foreign Account Tax Compliance Act (FATCA) There is certainly a ground swell for the complete repeal of FATCA but is that likely and what would that mean in the context of the global acceptance of the Common Reporting Standard (CRS)? In fact, the Administration of President Trump has been somewhat silent on this point.
Tax Planning for Ownership of US Real Estate
ax rules governing US property ownership are insufferably complex and can have different implications for residents and non-residents. In this article, we outline some key considerations for prospective and existing US property owners.
You may be looking to buy a holiday home near Disneyland or have your eye on a potentially lucrative real estate investment opportunity. Either way, tax planning can be a minefield and throw up all kinds of challenges.
What might be considered a sensible move from an income tax or capital gains tax planning perspective, can present unwanted results from an estate or gift tax perspective and vice versa.
Non-Dom Tax Changes
The changes to the taxation of non-domiciled individuals and offshore trusts due to take effect from 6 April 2017 have been well publicised, and have been through two consultations and draft legislation published. However the provisions which were due to be included in the Finance Bill 2017, were, at the last minute omitted from the Bill. This leaves many non-doms in a position of uncertainty as to their tax position, particularly taking into account the UK general election on 8 June 2017, and Brexit.