U.S. Tax Tips
Aug 21, 2020
There are a couple of developments on the GILTI front that readers may find interesting. First, last month the IRS issued final and proposed regulations involving GILTI and the high-tax exclusion. Second, one of Democratic U.S. Presidential nominee Joe Biden’s tax proposals is the doubling of the effective GILTI corporate tax rate from 10.5% to 21%.
To understand the potential impact of these, you first need to have a general understanding of what the GILTI provisions are meant to do and their current impact.
Jun 23, 2020
It is a fairly common estate planning technique in the United States to utilize a revocable living trust (“RLT”) as part of a “United States person’s” estate planning. For U.S. estate tax purposes, a United States person would include a U.S. citizen and a U.S. domiciliary. What is not so common though, is the potential foreign impact when the underlying U.S. grantor moves to a foreign jurisdiction.
Jun 08, 2020
In prior U.S. Tax Tips we discussed the requirements for qualified U.S. taxpayers to receive the Economic Impact Payment. The Economic Impact Payment (“EIP”) is part of the CARES Act and represents a pre-payment of a 2020 tax credit of US $1,200 per “eligible individual” and an addition US $500 per “eligible child.” Technically this credit will be claimed as part of their U.S. personal income tax return (if one is required to be filed). The payment is not limited to U.S. residents but includes “eligible individuals” who live outside the United States. Many of our clients have received their payments.