The Resource When intended estate planning results in an accidental inversion

When intended estate planning results in an accidental inversion

Label
When intended estate planning results in an accidental inversion
Title
When intended estate planning results in an accidental inversion
Creator
Subject
Language
eng
Summary
The transfer of shares by non-U.S. individuals of an existing U.S. corporation owning U.S. real estate to a newly formed foreign corporation in exchange for shares of the foreign corporation can have disastrous U.S. estate tax consequences for the non-U.S. domiciliary on death. This article discusses one variation of the "inversion" transaction, which involves the transfer of shares by non-U.S. individuals of an existing U.S. Subchapter C corporation owning U.S. real estate to a newly formed foreign corporation in exchange for shares of the foreign corporation (Share Inversion). It then describes the effect of the Share Inversion and associated anti-inversion rules on the recipient foreign corporation and its non-U.S. individual owners
Citation source
In: Journal of international taxation. - New York. - Vol. 27 (2016), no. 6 ; p. 26-35, 63-64
http://library.link/vocab/creatorName
  • Moore, R.H
  • Bruno, M.J
Language note
English
http://library.link/vocab/subjectName
  • corporate inversion
  • anti-inversion
  • inheritance tax
  • CFC
Label
When intended estate planning results in an accidental inversion
Instantiates
Publication
Label
When intended estate planning results in an accidental inversion
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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