Publication
Real Estate Focus - December 2024
December has been a very busy month, with a flurry of new government policies and consultations.
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
Recent publications
Publication
Essential Corporate News – Week ending 20 December 2024
On 13 December 2024 the Financial Conduct Authority (FCA) published Primary Market Bulletin 53 (PMB 53) which includes confirmation of the final form of two new, and one amended, sponsor-related technical notes previously consulted on in PMB 50, and a consultation on various proposed changes to the technical and procedural notes in the FCA’s knowledge base.
Publication
Dashboards update: webinars hosted by Pensions Regulator and Money and Pensions Service
The Regulator has provided a link to its dashboard webinar held on November 26, 2024, which it urges scheme trustees to watch. The Money and Pensions Service also collaborated with the Pensions Dashboard Programme to host a “town hall” dashboard event on December 2, 2024.
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