The PFIC regime has been in existence since 1986. Introduced in the Tax Reform Act, the regime closed a loophole. Prior to the change, assets could be transferred to entities organized outside the U.S., in order to escape U.S. taxation. As with other foreign...
Trusts are a way of life in N.Z. They are quintessentially used for a variety of purposes. Estate planning, asset protection, and wealth management are common examples. Whilst especially so for high-net-worth individuals and their families, trusts have formed part of...
Many countries develop and manage their tax policies to influence socio-economic behaviour. N.Z. is one such example. N.Z. has traditionally been slow to prepare its inhabitants for retirement. Other countries have had compulsory superannuation for decades, such as...
The 2022 filing season finished yesterday, 17 October 2022. Below are some statistics from this year’s filing season. These provide insight into the IRS’ processing of U.S. federal income tax returns through the 2022 season. Data is from the midyear report...
The IRS has completed its four-year foreign trust campaign. The campaign, launched on May 21, 2018, was one of six campaigns initiated by the Large Business and International (LB & I) units of the IRS. The crackdown on late foreign trust reporting to the IRS was...
