May 24, 2024

In recent years, several clients have faced heavy penalties for the late filing of Form 3520-A, known as the “Annual Information Return of Foreign Trust With a U.S. Owner.” Surprisingly, these penalties were assessed even when clients had filed a timely substitute Form 3520-A. This practice by the IRS contradicts its own published guidance. Fortunately, […]

Planning strategies that split a property into usufruct and bare ownership interests are common in civil law jurisdictions, serving various tax and non-tax goals. However, these divisions can pose challenges in common law jurisdictions, particularly in determining tax implications. When there’s no common law counterpart, authorities often resort to analogies with common law structures. The