Trump Estate Tax Plan Outlook at Mid-December, 2016
Under current US law, for 2017, the estate and gift tax exemption will be $5.49 million per individual, up from $5.45 million in 2016. That means an individual can pass $5.49 million to his or her heirs and pay no federal estate or gift tax. Surviving spouses can port over each other’
Read MoreDecember 20, 2016
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Robert Kiggins Moderates International Tax Panel
On March 8, 2016 Robert Kiggins moderated a panel discussion in New York City sponsored by The International Business Structuring Association based in London, England. The panel discussion focused on “How the Global Tax Environment is Changing the Way Companies Do Business.” The prog
Read MoreApril 12, 2016
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BEPS -Double Irish/ Dutch Sandwich Hybrid Entity Mismatches – Part II of II
THE CLASSIC DOUBLE IRISH WITH A DUTCH SANDWICH (“DIDS”) In Part I of this article, I discussed the mechanism by which some very prominent U.S. multinational companies have been able to reduce global income tax on mobile income, such as royalties on sales of software to, at times, almo
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BEPS -Double Irish/ Dutch Sandwich Hybrid Entity Mismatches – Part I of II
On Monday, October 6, 2015 the OECD (of which the US is a member) delivered its long awaited final BEPS (Base Erosion Profit Shifting) Action Plans. BEPS, which actually has 15 action points, is designed to set up a fair system of global taxation taking into account the global ta
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Treasury Drafts Proposals for US Model Income Tax Treaty
On July 14, 2015 Robert Kiggins moderated a panel discussion in New York City sponsored by The International Business Structuring Association based in London, England on the Treasury Draft Proposals for the next US Model Income Tax Treaty which were released May 20, 2015. The US Model
Read MoreAugust 05, 2015
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European Commission Attacks Luxembourg Amazon Hybrid Structure As Illegal State Aid
Introduction On January 16, 2015 the European Commission (“EC”) released its report that certain favorable tax rulings Luxembourg granted Amazon (circa 2003) have been preliminarily deemed to constitute illegal state aid under European law. State aid occurs when a European Union count
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