Controlled Foreign Corp. Restructuring for US Taxpayers

Publisher: Law360

August 13, 2018

Day Pitney Author(s) Carl A. Merino Dina Kapur Sanna

Carl Merino and Dina Kapur Sanna authored an article, "Controlled Foreign Corp. Restructuring for US Taxpayers," which was published in Law360. The article discusses how the Tax Cuts and Jobs Act (TCJA) impacts international private clients. As discussed in the article, TCJA provisions targeting U.S. multinationals doing business abroad, including the transition tax on deferred foreign income, the new GILTI tax regime and other changes to the rules governing controlled foreign corporations, dramatically affect the taxation of U.S. individuals who own closely held foreign companies. These changes will force re-examination of many existing tax structures, including succession planning structures set up by non-U.S. individuals for U.S. beneficiaries. "In considering possible workarounds, U.S. taxpayers face a rapidly changing tax and legal landscape both in the U.S. and abroad and will need to carefully weigh the impact of any restructuring proposals on their tax planning overseas," Merino and Sanna wrote.

Partner Dina Kapur Sanna spoke at the Private Client TransTrusts Bermuda event on a panel titled, “Impact of regulation, Economic Substance, Beneficial Owner Registers, FATCA, CRS across jurisdictions,” on June 4.

June 4, 2021

Private Client TransTrusts Bermuda, Webinar

NYSBA Spring Mtg - Planning for Hard to Value Assets in Uncertain Times: A Guide for Art Collectors

On May 6, Caryn R. Young and Emily A. Belfer present "Planning for Hard to Value Assets in Uncertain Times: A Guide for Art Collectors" at the Spring Meeting of the New York State Bar Association's Trusts and Estates Law Section.

May 6, 2021

New York State Bar Association (NYSBA) Webinar

Retroactive Tax Legislation and Gift Planning in 2021

March 25, 2021

Daniela P. Catrocho and Richard D. Sanders authored the article, "Retroactive Tax Legislation and Gift Planning in 2021," which was published in the New Jersey Law Journal.

"Little-Known Wrinkles in Foreign Trusts – Skills to Avoid Pitfalls in Practice," 16th Annual International Estate Planning Institute: Part 2

On March 18, Day Pitney Partners Dina Kapur Sanna and Carl Merino will participate at the 16th Annual International Estate Planning Institute hosted by the New York Bar Association and the New York chapter of the Society of Trust and Estate Practitioners (STEP NY).

March 18, 2021

Dina Kapur Sanna Co-Chairs 16th Annual International Estate Planning Institute: Part 2

Partner Dina Kapur Sanna will co-chair the 16^th Annual International Estate Planning Institute: Part 2, hosted by the New York Bar Association and the New York chapter of the Society of Trust and Estate Practitioners (STEP NY).

March 18, 2021

Day Pitney Completes Merger with Rhode Island Firm

July 16, 2021

Day Pitney's merger with Rhode Island-based Howland Evangelista Kohlenberg, which was completed on July 1, was featured in the Connecticut Law Tribune.

South Florida Law Firm Continues Expansion After Merging With Rhode Island Firm

July 15, 2021

The completion of the merger between Day Pitney and Howland Evangelista Kohlenberg was featured in South Florida Business & Wealth's article, "South Florida Law Firm Continues Expansion After Merging With Rhode Island Firm."

Day Pitney Completes Merger With Howland Evangelista Kohlenberg

July 12, 2021

Day Pitney's merger with Howland Evangelista Kohlenberg, which was completed on July 1, was featured in the MetroHartford Alliance.

Day Pitney Expands to RI With Completed Trusts Firm Merger

July 9, 2021

The completion of the merger between Day Pitney and Howland Evangelista Kohlenberg was featured in Law360 Pulse's article, "Day Pitney Expands to RI With Completed Trusts Firm Merger."

Day Pitney Completes Merger with Rhode Island Law Firm

July 9, 2021

Day Pitney's completion of its merger with Rhode Island trusts and estates boutique Howland Evangelista Kohlenberg was featured in Hartford Business Journal.