McGuire Woods has posted an article on its website discussing the Tax Reduction Opportunities for Non-U.S. Families, Family Offices and Trusts created by the Tax Cuts and Jobs Act. The introduction to the article is as follows:
Although virtually all of the tax community’s coverage related to the 2017 Tax Act focuses on its impact on U.S. taxpayers, the new law also provides historic opportunities for non-U.S. families, family offices and trust structures currently or otherwise interested in investing in the U.S. to dramatically reduce their U.S. federal tax exposure. Widely considered the most significant overhaul of the U.S. tax code since 1986, existing U.S. inbound structures should be reviewed to optimize the effect of the 2017 Tax Act’s new changes, and new structures should be designed to realize maximum benefit from these new changes.
In short, the old rules and conventions used to design U.S. inbound investment and family structures prior to the 2017 Tax Act may no longer result in the lowest U.S. income tax exposure and may unnecessarily increase a non-U.S. client’s exposure to U.S. estate and gift taxation.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.