Publication
International Restructuring Newswire
Welcome to the Q2 2025 edition of the Norton Rose Fulbright International Restructuring Newswire.
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.
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Co-head of Tax, United States
Email
bill.cavanagh@nortonrosefulbright.com
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Hospitals on losing end of Medicare DSH dispute, Supreme Court rules
As the hospital industry eyes continued cuts to Medicare and Medicaid reimbursement, the US Supreme Court, this week, dealt another blow in its ruling in Advocate Christ Medical Center et al. v. Kennedy, Secretary of Health and Human Services, April 29, 2025.
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