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U.S. Owners of Foreign Corporations Face New Hurdles

Publisher: Trusts & Estates
April 2019
Day Pitney Author(s) Carl A. Merino

Carl Merino authored an international practice feature article, "U.S. Owners of Foreign Corporations Face New Hurdles," published in the April 2019 issue of Trusts & Estates magazine. The article discusses the impact of the Tax Cuts and Jobs Act of 2017 (TCJA) on U.S. individuals who own stock in controlled foreign corporations, with a focus on the new tax on global intangible low-taxed income (GILTI) and potential mitigation strategies.

Recommended
Where Should I Locate My Structures?

Day Pitney Partner Dina Kapur Sanna was a panelist on the session, "Where Should I Locate My Structures?," at the Transcontinental Trusts International Virtual Conference.

September 3, 2020
Day Pitney's Palm Beach Family Office Forum 2020 Update

Due to the COVID-19 pandemic, this year's annual Day Pitney Palm Beach Family Office Forum, which had originally been scheduled for April 28 and 29, has been postponed to hopefully be rescheduled for later this year.

April 28-29, 2020
COVID-19 Impact on Tax Filings in Florida
April 28, 2020

Day Pitney Advisory

IRS Provides Limited Relief to Cross-Border Taxpayers Stranded by COVID-19
April 28, 2020

Day Pitney Advisory

IRS Provides Limited Relief to Cross-Border Taxpayers Stranded by COVID-19
April 28, 2020

Day Pitney Advisory

Domicile Changes and Audits Increase in Connecticut
May 15, 2020

Glenn Rybacki gives an in-depth summary on what domicile is and the preparations necessary for a potential audit in "Domicile Changes and Audits Increase in Connecticut," his latest entry in State Tax Notes.

COVID-19 & Election Year Wealth Transfer Strategies
May 8, 2020

On May 8, Amy Lonergan was a panelist on a webinar, "COVID-19 and Election Year Wealth Transfer Strategies," hosted by the Family Wealth Alliance.

Day Pitney Promotes Five New Partners
January 2, 2020

Day Pitney Press Release

Day Pitney Represents Pula Capital Management LP in Strategic Investment by Felton Group, LLC
December 3, 2019

Day Pitney LLP represented Pula Capital Management LP (Pula), a newly formed investment manager based in Virginia, in connection with (i) the acquisition of a minority ownership interest in Pula by Felton Group, LLC (Felton Group), and (ii) an investment by Felton Group in Pula Capital Fund, LP, a newly formed fund managed by Pula that intends to employ novel mathematical techniques and a proprietary, systematic predictive model to trade a diversified long-short portfolio of liquid U.S. equities.

Day Pitney Receives Top Rankings in U.S. News – Best Lawyers “Best Law Firms”
November 12, 2019

Day Pitney Press Release

Firm Ranked Tier 1 Nationally for Energy Law and Trusts and Estates Law
Related Professionals
Merino, Carl
Carl A. Merino
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