International Services  |  By Ladidas Lumpkins, CPA, JD, LL.M.

US Tax Compliance for Foreign Trusts: A Primer

A threshold question in determining how a trust will be taxed in the US is whether the trust is foreign or domestic. The default rule is that a trust is foreign, unless the trust fails both the “Court Test” and the “Control Test.” The Court...

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International Services  |  By Fernando R. Lopez, JD, MBA

US International Tax Reform: Overview of New US Tax Landscape and Planning Opportunities for US and Foreign Companies

Congress bestowed a tremendous holiday gift to the global corporate community in the form of a significantly reduced U.S. corporate tax rate and full expensing of plant and equipment acquisitions that effectively lays out the red carpet to foreign...

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International Services  |  By Jack Brister, TEP

Foreign Trusts: An Answer to the Capital Loss Debate

The enactment of the Small Business Job Protection Act of 1996 expanded the differences in grantor trust rules for foreign and domestic trusts. At the same time, it narrowed the distributable net income (DNI) computation rules for foreign trusts....

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