Major Provision in New Tax Laws

    In the past 12 months (starting late December 2017), we have seen perhaps the most significant changes to tax laws since the last major tax reform in 1986. These changes came from all three branches of the government. Congress passed the “Tax Cuts and Jobs Act of 2017” (“TCJA”) and the President [...]

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      A Tax Sandwich – Not Tasty At All

      When a foreign investor becomes a U.S. tax resident, one easily overlooked U.S. tax issue is that such residence change may result in an adverse U.S. tax structure, sometimes referred to as a “Sandwich Structure.” What is a Sandwich Structure? Let’s use an example to explain what a Sandwich [...]

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