Publication
Reducing wildfire-related D&O liability risk
Recent catastrophic wildfires in California and Hawaii have intensified public scrutiny of utilities and other companies that operate in areas susceptible to wildfires.
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
BOI reporting removed for US companies and persons
FinCEN's interim final rule that removed the requirement for US companies and persons to submit beneficial ownership information (BOI) reporting under the CTA was published in the Federal Register.
Publication
Corporate Transparency Act reporting obligations
The Corporate Transparency Act (CTA) is a United States law designed to enhance law enforcement’s ability to combat money laundering, terrorist financing and other illicit activities by increasing transparency with respect to owners of closely held business structures.
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