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 […]

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 […]

On March 21, 2023, the Treasury Department and the Internal Revenue Service (the “IRS”) announced that they were requesting comments regarding upcoming guidance on US tax treatment of certain nonfungible tokens (“NFTs”) as collectibles under Internal Revenue Code (IRC) section 408(m). NFTs An NFT is a unique digital identifier that is used to certify ownership and […]

Written by Johana Regatuso and Harry Swift.  Chancellor Jeremy Hunt has now delivered his statement on UK tax and spending. Out of the past five Chancellors, he is only the second to hold the iconic red box outside No. 11 Downing Street. There has been very little in the press in the run-up to this […]

Even as venture capital markets expand around the world and forge new hubs for business, the unique allure of the US remains constant. The US boasts a vast and affluent base of consumers, robust supply chains and infrastructure, as well as a wide diversity of markets. At some point most businesses will think about US […]

American citizens and resident aliens are all too familiar with the IRS practice of worldwide taxation. For most expats, this simply means having to file an additional tax return each year. But where the rules can get complex and, in many cases counter-intuitive, is where these rules extend their reach into overseas assets owned by […]

USTAXFS UK appoints ex-EY Frank Hirth’s, Glenn Snow, as Tax Director in its Private Client Group, alongside a series of strategic hires and promotions We are delighted to announce that USTAXFS UK has appointed award-winning industry star Glenn Snow, formerly EY Frank Hirth, to the position of Tax Director within the Private Client Group. The […]