With rising life expectancies, it is possible that individuals will outlive their traditional retirement savings. A qualified longevity annuity contract (QLAC) provides a potential solution. What is a QLAC? A QLAC is a fixed deferred annuity, meaning it ensures a continuous stream of income from an agreed-upon start date. This guaranteed income stream is achieved […]

USTAXFS Tax Director, Patrick Hoza, provides the latest on US Estate Tax concerns for non-US persons. The United States imposes its Estate Tax not only on its citizens and residents but also on non-residents that die owning US situs assets. So, what might be taxable? Non-resident aliens (NRAs) are taxed on certain categories of US […]

The Corporate Transparency Act will require certain US entities (and certain foreign entities) to report information relating to their ultimate Beneficial Owner to FinCEN. FinCEN issued its Final Rule implementing the CTA on September 29,  setting the enforcement date to be January 1, 2024. This new Act and its reporting obligations are discussed in detail […]

If you are a US taxpayer (citizen, Green Card holder or resident) living abroad, this time of year can be taxing in every sense. Tax Filing Due Date Individual Income Tax Returns are normally due on April 15th. However, if the 15th falls on a weekend or national holiday the deadline is extended. For 2023 […]

A trust is a legal arrangement where the creator of the trust (called either a grantor or settlor) transfers legal title to property to a trustee to manage for the benefit of individual(s) or entities (such as a charity). The person(s) or entities for whom the property is managed are called “beneficiaries”. The trust may […]

An overview of Global Intangible Low-Taxed Income (GILTI)  Prior to the enactment of the 2017 Tax Cuts and Jobs Act (“TCJA”), the United States generally taxed US taxpayers on their worldwide income. However, US tax on foreign subsidiaries’ active business earnings could be deferred until such earnings were repatriated to the United States. The Global […]

The Tax Cuts and Jobs Act (TCJA) created significant changes for both taxpayers and practitioners. One of the most disruptive and wide-ranging changes to taxpayers of TCJA was the repeal of Internal Revenue Code (IRC) Section 958(b)(4), effective as of January 1, 2018. Background A foreign corporation is treated as a controlled foreign corporation (CFC) […]