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Self-Directed IRAs (SDIRA) and Golden Visas
Episode 1754
In this episode, we explore how U.S. investors are using Self-Directed IRAs (SDIRAs) to participate in Golden Visa programs across Europe — particula…
1 year ago
Wyden Draft Bill: An Existential Threat to the PPLI Industry
Episode 1753
The Wyden Draft Bill, formally part of the Modernization of Derivatives Tax Act discussion, poses a potential existential threat to the Private Place…
1 year ago
One Big Beautiful Bill Act Aligns U.S. International Tax Rate with Global Norms
Episode 1752
The One Big Beautiful Bill Act (OBBBA) represents one of the most significant shifts in U.S. international tax policy since the 2017 Tax Cuts and Job…
1 year ago
One Big Beautiful Bill Act (OBBBA) - No More Uncontrolled Downward Attribution?
Episode 1751
When the Tax Cuts and Jobs Act (TCJA) repealed section 958(b)(4) back in 2017, it unleashed chaos across the cross-border tax landscape. The repeal a…
1 year ago
One Big Beautiful Bill Act (OBBBA) - From GILTI to NCTI
Episode 1750
The One Big Beautiful Bill Act (OBBBA) quietly rewrote one of the most consequential areas of U.S. international tax — rebranding GILTI (Global Intan…
1 year ago
Millionaire Flight Narrative
Episode 1749
In 2024, headlines screamed of a millionaire “exodus” from the UK and other countries—10,900+ news pieces carried the story. The supposed flight of t…
1 year ago
How Advisors Protect Themselves by Informing Clients
Episode 1748
When does technical advice cross into criminal risk—and how can advisors protect themselves?
If an advisor tells a U.S. client:
“Yes, Svalbard’s unique…
1 year ago
Advisor Liability Under FATCA
Episode 1747
Can an advisor get into trouble for giving technically true—but incomplete—advice? Under FATCA, the answer is yes.
Take the example of Svalbard. Norwa…
1 year, 1 month ago
Is It Illegal to Avoid FATCA?
Episode 1746
Owning foreign accounts or assets isn’t illegal, and it’s not inherently unlawful to fall outside FATCA’s scope. The real issue is knowing what count…
1 year, 1 month ago
What Is an Expanded Affiliated Group (EAG) in FATCA
Episode 1745
An Expanded Affiliated Group (EAG) is defined under Code section 1504(a) and Treas. Reg. §1.1471-5(i). It generally means one or more chains of entit…
1 year, 1 month ago