Recent Posts in February, 2019

• Treaty-Based Synthetic Basis Step-Up Election for Australian Nationals
  Feb 22, 2019
  by John Anthony Castro, J.D., LL.M. Introduction One issue that comes up quite frequently from Australian nationals in the U.S. is the fear that the ...
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• The UK LTA Charge Can Be Claimed as a U.S. Foreign Tax Credit
  Feb 21, 2019
  by John Anthony Castro, J.D., LL.M. Introduction Although this article concludes that the Lifetime Allowance Charge, also known as the LTA Charge, is ...
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• U.S. Roth Accounts are Exempt from UK Tax | QROP Loophole | Hopscotch U.S. Extraction
  Feb 18, 2019
  by John Anthony Castro, J.D., LL.M. UPDATE Please note that the HMRC is currently being uncooperative and not approving any new QROP applications for ...
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• The 2019 Offshore Voluntary Disclosure Program | 2019 OVDP
  Feb 8, 2019
  by John Anthony Castro, J.D., LL.M. Introduction On November 20, 2018, the Deputy Commissioner for Services and Enforcement, Kirsten B. Wielobob, ...
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• The Treaty Definition of a Permanent Establishment
  Feb 7, 2019
  Introduction We advise clients worldwide on structuring operations to avoid the finding of a permanent establishment. Contact us to schedule a free ...
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• Section 267(b)(1) Related Family Members
  Feb 6, 2019
  Introduction Section 267(b) is referenced in 79 sections throughout the Internal Revenue Code as well as 175 state law provisions for the definition ...
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• The Net Investment Income Tax is Eliminated by Totalization Agreements | NIIT Exemption
  Feb 5, 2019
  by John Anthony Castro, J.D., LL.M . Introduction One of the most common and frequent questions we get from clients outside of the U.S. is “why do I ...
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• The New Section 163(j) Interest Limits and the Portfolio Interest Exemption
  Feb 4, 2019
  by John Anthony Castro, J.D., LL.M. Introduction On December 22, 2017, the President signed into law the Budget Fiscal Year 2018, which made drastic ...
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