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US Treatment of Swiss Pensions – 2nd pillar

The Swiss employee pension plan (known as the 2nd pillar pension), is, from a US tax perspective, a funded non-qualified foreign pension plan.  As such, contributions employees make to the plan are non-deductible from a US perspective and the company contributions to employee plans are considered taxable wages. We include the growth in the plan as […]

Update: GILTI tax

Update: Since this blog was posted, the IRS issued proposed regulations, on March 3, 2019, that clarifies that the 50 percent deduction discussed in item 5 will be available to individual shareholders who elect to be taxed as a corporation.   Last year we provided an early update that all US shareholders of Controlled Foreign Corporations (CFC) […]

2019 US Tax Deadlines for 2018 calendar year returns

Below is a list of 2019 US tax deadlines to note for 2018 tax returns. January 17, 2019 Deadline for Individuals to pay Quarter 4 of their 2018 Estimated Income Tax payment. If you have income that does not have US Federal tax withholding or the income cannot be offset using deductions or foreign tax […]

Top 5 2018 US Tax Return Changes

This is a brief summary of some 2018 US tax return changes that may affect your tax return. Standard Deduction Under the new law, the standard deduction for all taxpayers has increased from 1 January 2018. This is intended to significantly reduce the number of taxpayers who itemize their deductions. Itemised Deduction State & Local taxes […]

Non-Domiciled Alien Estate Taxes in the US: US assets

Many people have assets in the US, but if you are not a US citizen or tax resident (domiciled) of the United States you will want to understand how your US assets will be taxed once you pass away. Under the current law, “non-domiciled aliens” who own or have an interest in US situated assets […]

US Tax Reform – Estate and Gift Tax Implications

The Tax Cuts and Jobs Act provides US persons certain beneficial estate planning opportunities. Below are a few highlights of the Act that impact estate planning. Estate Tax For any US individual dying after December 31, 2017, the Act increases the federal estate tax exemption amount to $11.18 million (from $5.49 million in 2017). The […]

Trust structures complexities

US settlors and US beneficiaries of non-US trust face a myriad of US income tax and reporting obligations that are not imposed on US settlors and US beneficiaries of US trust. In the first instance, both settlors and beneficiaries must report the income and gains of the trust allocated to them on their US income […]

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