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’s unused exemptions, allowing […]

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 program included: Recent developments in the OECD BEPS (base erosion and profit shifting) implementation, […]

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, almost nil by routing such income through […]

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 tax issues that have arisen from […]

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 was last updated in 2006 so this is […]

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 country grants advantages (e.g. grants, interest and tax reliefs, guarantees, government holdings of all […]