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 […]

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 […]

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) […]

On April 3, 2023, the United States Tax Court ruled in Alon Farhy v. Commissioner, 160 T.C. No. 6 that the Internal Revenue Service (IRS) did not have authority to assess penalties under Internal Revenue Code (IRC) section 6038(b) against a taxpayer who willfully failed to file Form 5471, Information Return of US Persons With Respect […]

Loans to or from a foreign trust by US persons may be treated as either a contribution to the trust, or a distribution from the trust. Qualified Loan To avoid this treatment the loan must be a “Qualified Loan”.   To be a “Qualified Loan” the following requirements must be met: The obligation must be in […]

USTAXFS underpins the Corporate and Funds Tax Group exponential growth with key regional promotions  We are pleased to announce that USTAXFS has promoted two senior team members in both London and Geneva into Director positions. Inna Ganz in Geneva and Stacy Martin in London are now US Tax Directors within the fast-growing Corporate and Funds […]