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I wanted to take a deeper dive into U.S. Trusts as I see it as perhaps the most powerful of tax planning tools available to my clients. I will do so in a series of articles over this year – 2021 What is a “Grantor Trust”? To refresh our memory, a grantor trust is a […]
Benefits of PPLI Private Placement Life Insurance (PPLI) is a specialized life insurance policy that caters to the needs of high-net-worth individuals and business proprietors. Here are the main advantages of PPLI: Expanded Investment Opportunities: PPLI policies generally provide a wider array of investment opportunities than standard life insurance policies, including alternative investments like hedge
Madeira – Investment Trends In Portugal, there are different types of companies, each with its own unique characteristics. The differences mainly relate to the number of shareholders and their respective level of responsibility, how the capital is represented, and the management and supervision. Here are the main types of companies in Portugal: Private Limited Companies
Let’s Talk about tax in Madeira Read More »
An Outlook on the Future of the NHR / Golden Visa in Portugal On October 10th, the Portuguese Government presented the 2024 Budget Bill. The draft foresees the termination of the current NHR for new applications from January 1, 2024. Current beneficiaries and those who register as NHR until its termination will maintain all benefits.
Advanced Tax Planning Guide for American Taxpayers in Portugal Read More »
Soon after the Tax Cuts and Jobs Act was enacted in 2017, the problems caused by the repeal of section 958(b)(4), commonly referred to as a limitation on the downward attribution of stock ownership from foreign to U.S. persons, became increasingly apparent. Defining Key Terms For Understanding the Attribution Rules and Form 5471 U.S. Person Only U.S.
What do I do if I have a delinquent international information return? Taxpayers who have identified the need to file delinquent international information returns who are not under a civil examination or a criminal investigation by the IRS and have not already been contacted by the IRS about the delinquent information returns should file the
Delinquent International Information Return Submission Procedures – The Ultimate Guide Read More »
Low-tax jurisdictions typically do not pose significant issues. However, exercise caution when dealing with low-tier jurisdictions of poor reputation, as they can present challenges. Several reasons contribute to this, including: Legal risks: Relocating to a jurisdiction with a poor reputation could expose you to legal vulnerabilities. Transparency is now an international initiative and reputable jurisdictions
Should you Opt for Low-Tier Tax Jurisdictions to Avoid New Transparency Rules? Read More »
The future of golden visas is uncertain. On one hand, there is an increasing demand for these schemes from wealthy individuals who are seeking to secure residency or citizenship in other countries. On the other hand, there is growing scrutiny of these schemes from governments and regulators who are concerned about their potential for abuse.
What About the Future of Golden Visas? Read More »
Here are some factors to consider when choosing which country to open a bank account: Your residency: Some countries only allow residents to open bank accounts, while others allow non-residents as well. If you’re not a resident of the country you’re considering, you’ll need to check the residency requirements. The country’s financial stability: You’ll want
How to Choose Where to Bank? Read More »
https://youtu.be/ZaRecqW1UdA What Makes the Brazilian Tax System One of the Most Complex in the World? Brazil’s tax system is complex for several reasons, including: Historical factors: Brazil has a long history of tax complexity, dating back to the colonial period. The tax system has been shaped by various factors, including the country’s large size and
Advanced Tax Planning for Brazil Read More »