Publication
US/Ukraine minerals deal: Digging into the detail
The United States and Ukraine governments have announced the signature of an agreement of a minerals deal for Ukraine.
Foreign nongrantor trust for US beneficiaries: dos and don’ts
United States | Publication | April 2022
The throwback tax is the US tax law’s main tool for discouraging tax-free accumulation of income by foreign non-grantor trusts for US beneficiaries. Its complex rules are a dangerous minefield that should be avoided. This article reviews the operation of the throwback tax rules, and assesses the effectiveness of this trust anti-deferral regime in various fact patterns. It also discusses how the trust anti-deferral regime interacts with the US law’s foreign corporation anti-deferral regime, another minefield.
Download the Oxford Academic's Trusts & Trustees reprint
Co-head of Tax, United States
Email
bill.cavanagh@nortonrosefulbright.com
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