Publication
International arbitration report
In this edition, we focused on the Shanghai International Economic and Trade Arbitration Commission’s (SHIAC) new arbitration rules, which take effect January 1, 2024.
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
ECJ confirms public tenders’ restrictions for companies from third countries with no procurement agreement with the EU
EU Member States may allow companies from countries that have not concluded an agreement guaranteeing equal and reciprocal access to public procurement (public procurement agreement) with the EU to participate in public tenders, provided there is no EU act excluding the relevant country.
Subscribe and stay up to date with the latest legal news, information and events . . .