25 Sep 2019
Alternative asset management – USA state and local tax update
On Thursday, September 26, Andersen United States will host a webcast on state and local tax and how recent updates have impacted the Alternative Investment industry.
4 Aug 2019
Non-US individuals, trusts and companies investing into the US
The tax treatment of US investments differs depending on whether the investor is an individual, company or trust. Investors need to understand the consequences of different investment structures so that they can plan their investment decisions for maximum tax efficiency.
18 Jul 2019
GILTI regs improve position for partnerships owning CFCs
Partners in private equity and domestic partnerships will benefit from these regulations if they do not own directly, indirectly or constructively 10% or more of the stock of a foreign corporation and thus will not be required to have a GILTI inclusion. The final regulations are applicable for tax years beginning after December 31, 2017.
4 Jul 2019
US estate taxes for non-Americans
Non-US individuals owning US assets could be exposed to US gift and estate tax on death or when the asset is gifted. Such individuals should seek advice to understand the level of exposure and whether any pre-emptive planning can be undertaken.
20 Jun 2019
IRS Issues Final and Proposed Regulations on GILTI
The IRS and Treasury have released final and proposed regulations regarding the new global intangible low-taxed income (GILTI) regime, applicable to US taxpayers with interests in foreign companies.
25 Jan 2019
Final Regulations on 20% Pass-Through Deduction Resolve Various Uncertainties
IRS and Treasury have released final regulations under Sec. 199A of the Internal Revenue Code (Code) regarding the 20% deduction for pass-through entities and certain individuals.
13 Dec 2018
Non-Americans investing into the US post-tax reform
The individual tax provisions of tax reform present opportunities for non-resident non-Americans investing into the US.
1 Nov 2018
US tax reform and fund manager carried interest
We highlight uncertainties resulting from the tax reform provisions for fund managers’ carried interest.
9 Oct 2018
US Tax Reform – implications for individuals
In this article we provide an overview and commentary on the key tax reform provisions affecting high net worth individuals.