Using Brazilian investment funds is an important wealth planning tool for Brazilian families who are considering US tax residency, say Gessimbergue Monteiro of G.S. Monteiro Law and Felipe Medaglia of Souza Okawa.
Paul DePasquale of Baker McKenzie and Flávia Gerola of Trench Rossi Watanabe address usufructs as a wealth-planning tool for Brazilian families and relevant points of attention when dealing with US connections.
George Clarke, Sonya Bishop, Joseph Judkins, Ethan Kroll, Vivek Patel, and Varuni Balasubramaniam of Baker McKenzie analyze the upcoming decision by the Supreme Court in Moore v. United States on the constitutionality of the transition tax under the Tax Cuts and Jobs Act of 2017 and how taxpayers can recover a 2017 tax in 2024 if the transition tax is held unconstitutional.
Editor’s Note: This column reports on significant bills introduced in the 117th Congress that would affect international provisions of the Internal Revenue Code. Bills are listed in chronological order, based on the date of introduction. New material is indicated in bold italics, and the column is current of Bills made available on Congress.gov as of June 30, 2023.
Monique van Herksen and Clive Jie-A-Joen of Simmons & Simmons, Jolanda Schenk of Shell Netherlands, and Marc Levey of Baker McKenzie discuss their personal perspectives on the global commitment to reduce Green House Gas emissions and how international coordination is necessary to aid and encourage compliance by resolving administrative and legal challenges or inconsistencies so that companies and investors may benefit from clear and consistent treatment for tax and transfer pricing purposes.
Nathan Boidman and Peter Glicklich from Davies Ward Phillips & Vineberg LLP discuss H.R. 3665, proposed legislation introduced on May 25th in the GOP-controlled House of Representatives, that if adopted could impose retaliatory taxes (and possible future trade and other sanctions) on citizens and companies from countries that adopt the OECD-sponsored “Pillars.”
Salim Rahim, Summer Austin, Eric Torrey, and Amanda Worcester-Martin of Baker McKenzie discuss the new processes for the review and acceptance of APA requests and highlight areas where more clarity is needed.
Sahel A. Assar of Buchanan, Ingersoll & Rooney P.C. discusses the current often difficult, expensive, and unreasonable challenges taxpayers face to meet the qualified appraisal substantiation requirements to donate cryptocurrency to a charity.
In this second part of the two-part series, Melvin Warshaw and David Lesperance look at the interaction between tax and immigration law consideration and possible strategies for Israeli entrepreneurs considering a possible relocation from Israel to the United States.
In this first of two articles, Melvin Warshaw and David Lesperance focus on the immigration options involved in moving an Israeli businessperson and their family to the United States on a part- or full-time basis. In the second article in this series, they focus on the personal and business tax issues and strategies involved in a move out of Israel and into the United States.
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