The Resource Taxation of U.S. shareholders of foreign corporations after tax reform [part 1]

Taxation of U.S. shareholders of foreign corporations after tax reform [part 1]

Label
Taxation of U.S. shareholders of foreign corporations after tax reform [part 1]
Title
Taxation of U.S. shareholders of foreign corporations after tax reform [part 1]
Creator
Subject
Language
eng
Summary
In this first installment of a two-part article, the authors examine changes made by the Tax Cuts and Jobs Act (TCJA) that estate planners should consider if they represent U.S. taxpayers who have foreign investments, nonresident aliens (NRAs) who have U.S. investments, or estate plans that involve the transfer of assets owned by an NRA or a foreign trust to U.S. beneficiaries. The second installment will discuss planning strategies to mitigate some of the adverse tax consequences of the TCJA
Citation source
In: Tax notes international. - Falls Church. - Vol. 94 (2019), no. 11 ; p. 1085-1106
http://library.link/vocab/creatorName
  • Harrison, E.K
  • Lee, P.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • TCJA
  • CFC
  • passive foreign investment company
  • deferral
  • GILTI
  • FDII
  • foreign investment
  • non-resident alien
  • estate planning
  • foreign company
Label
Taxation of U.S. shareholders of foreign corporations after tax reform [part 1]
Instantiates
Publication
Label
Taxation of U.S. shareholders of foreign corporations after tax reform [part 1]
Publication

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