Tax and Estate Planning for Mexicans with U.S. Assets or U.S. Heirs

The One Big Beautiful Bill Act (OBBBA) introduces major international tax changes impacting U.S. taxpayers with cross-border interests as well as foreign investors in the United States. Key updates include the overhaul of anti-deferral regimes and tax incentives such as GILTI and FDII, new rules for...

Ryan J. Coyle discusses planning for U.S. beneficiaries of foreign trusts at the Estate Planning Council of Greater Miami’s January meeting.

The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal Revenue Code. To add confusion to the already complicated subject, the definitions of “contingent interest” or “contingent payments”...