Publication
Global rules on foreign direct investment (FDI)
Cross-border acquisitions and investments increasingly trigger foreign direct investment (FDI) screening requirements.
Foreign nongrantor trust for US beneficiaries: dos and don’ts
United States | 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.
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Co-head of Tax, United States
Email
bill.cavanagh@nortonrosefulbright.com
Recent publications
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Generative AI: A global guide to key IP considerations
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NRF Director of Strategic Innovation & Design named Innovation leader of the year at the ILTA 2024 awards
We are delighted to announce that Al Hounsell, Director of Strategic Innovation & Legal Design based in our Toronto office, has been named 'Innovative Leader of the Year' at the International Legal Technology Association (ILTA) Awards.
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