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Feature

  • Malaysia: Wealth management and tax planning in the wake of COVID-19

Case Summaries

Brazil

  • Private Letter Ruling No. 41 of 31 March 2020 — tax treatment of trust distributions to Brazilian beneficiaries

France

  • Wealth tax — The refusal to benefit from the 30% allowance on the market value of the principal residence held through a real estate company (French SCI) is constitutional

United States

  • US IRS private ruling — Modifications to trust agreement and creation of successor trusts did not cause unfavorable tax treatment for the trust

  • US beneficiaries may claim withholding tax credit for foreign non-grantor trust distributions

Legislative Developments

Argentina

  • Argentina offers repatriation of 5% of assets located abroad to obtain a reduction of the applicable Personal Assets Tax rate

Brazil 

  • Changes in the Transfer and Gift Tax ("ITCMD") legislation

United States

  • Reduced interest rates offer family estate planning opportunities amid crisis

  • IRS requests comments concerning information reporting on transactions with foreign trusts and on gifts from foreign persons

  • High net worth taxpayers face IRS wealth squad
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