Posts in February, 2019

Feb 22 Treaty-Based Synthetic Basis Step-Up Election for Australian Nationals

by John Anthony Castro, J.D., LL.M. Introduction One issue that comes up quite frequently from Australian nationals in the U.S. is ...

Feb 21 The UK LTA Charge Can Be Claimed as a U.S. Foreign Tax Credit

by John Anthony Castro, J.D., LL.M. Introduction Although this article concludes that the Lifetime Allowance Charge, also known as ...

Feb 18 U.S. Roth Accounts are Exempt from UK Tax | QROP Loophole | Hopscotch U.S. Extraction

by John Anthony Castro, J.D., LL.M. UPDATE Please note that the HMRC is currently being uncooperative and not approving any new ...

Feb 08 The 2019 Offshore Voluntary Disclosure Program | 2019 OVDP

by John Anthony Castro, J.D., LL.M. Introduction On November 20, 2018, the Deputy Commissioner for Services and Enforcement, ...

Feb 07 The Treaty Definition of a Permanent Establishment

Introduction We advise clients worldwide on structuring operations to avoid the finding of a permanent establishment. Contact us ...

Feb 06 Section 267(b)(1) Related Family Members

Introduction Section 267(b) is referenced in 79 sections throughout the Internal Revenue Code as well as 175 state law provisions ...