The United States imposes an estate or succession tax on the transfer of specific US situs assets owned by a person on death, even if the person was neither a citizen nor a resident of the United States at death (aka a non-domiciliary). US situs assets owned at the decedent’s death that are subject to […]

The Corporate Transparency Act will require certain US entities (and certain foreign entities) to report information relating to their ultimate Beneficial Owner to FinCEN. FinCEN issued its Final Rule implementing the CTA on September 29,  setting the enforcement date to be January 1, 2024. This new Act and its reporting obligations are discussed in detail […]

Over the past decade, pension plans have been established and licensed in Malta with particular consideration given to US taxpayers. A number of these plans were designed to accept “rollovers” from foreign pension plans owned by US persons – most notably from UK pension plans – combining the tax deferral benefits of a Qualifying Recognised […]

On August 24, 2022 the IRS issued Notice 2022-36 which provides failure-to-file penalty relief to many taxpayers who have late filed (or will late file) certain 2019 or 2020 tax returns. Included in this relief are the following income tax returns (not an exhaustive list): Form 1040 and 1040-NR Individual Tax Returns Form 1041 Tax Returns […]