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SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

09 Dec 2024 Written by

Article Written for:  TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

In Moore v. U.S. (36 F. 4th 930), the U.S. Supreme Court ruled on a constitutional challenge of IRC section 965, the mandatory repatriation tax (MRT).

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Pre-Immigration Planning and the Foreign Trust

Pre-Immigration Planning and the Foreign Trust

04 Oct 2024 Written by

Article Written for:  Florida CPA Today Magazine, FICPA Florida Institute of Certified Public Accountants

For U.S. income tax purposes, foreign trusts are treated as non-resident/non-citizens (NRNC), subject to U.S. income tax only on U.S. source income.[1]

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Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax

Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax

04 Mar 2024 Written by

Article Written for:  Florida Bar Journal

A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to U.S. income tax only on U.S. source income.[1]

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