It is not uncommon, in the context of a business entity in which a family owns a controlling or substantial interest, for an adviser to encounter intersecting gift and income tax issues. This week’s ...
On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by ...
In Private Letter Ruling 202406001 (Feb. 9, 2024), the taxpayer sought a determination of the gift tax consequences of a capital reorganization. An executive had previously formed several trusts and ...
Clearly, such a situation would have dramatic economic consequences in Europe and beyond, including, for example, the possibility of one or more countries leaving the euro or even a complete breakup ...
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