Volume 5 No 2    |    Read Article

By Sheryl Shah

Most cross-border tax advisers with clients that are impacted by the T.C.J.A. focus on the principal items, such as B.E.A.T., G.I.L.T.I., and the like. However, the act contains many additional provisions that can affect the non-corporate cross-border investor. Taxes have been reduced, a holding period for capital gains treatment now applies to carried interests, the scope of like-kind exchanges has been limited, and the tax treatment of alimony payments has been changed. These are just a few of the items addressed by Sheryl Shah.    See more →