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
États-Unis | Publication | avril 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
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