Singapore holding company with founders in Europe: where the operating company goes, why effective management decides residence (ITA s.2) and how EU CFC rules under ATAD treat the holding.
IP in a Singapore company under the IP Development Incentive (5%/10%, ITA s.43X, nexus) with the family in the UK: UK CFC rules (TIOPA 2010 Part 9A), central management and control, substance.
Jersey trust with an Italian-resident family: where to place the holding, how CFC rules (art. 167 TUIR) and trust interposition read the stack, and why effective management must stay out of Italy.
IR35 and the personal service company: Chapters 8 and 10 ITEPA 2003, the Ready Mixed Concrete test, the case law, the offset from 6 April 2024, appeal deadlines, cost, and the owner's move.
How tax systems see a trust: US grantor vs non-grantor, throwback and Form 3520, UK relevant property after FIG, Russian CFC rules and CRS transparency.
Hub for the tax section: three variables of the calculation, residence tests and exit tax, new-resident regimes, CFC rules, CRS, DAC8 and UBO registers.
How CFC and PFIC read one foreign company: the §1297(d) ordering rule, OBBBA parameters from 2026 (NCTI, 40% deduction, §958(b)(4)) and the exits that work.
Russia hub for private capital: the 183-day test and 13–22% scale, currency reporting, CFC rules, suspended tax treaties, personal foundations, payment routes.
A practical guide to U.S. tax residency, citizenship-based taxation, FATCA, FBAR, CFC, PFIC, trusts, family offices, cleanup and expatriation for Americans abroad.
UK tax residence, the FIG regime, worldwide income, offshore companies, trusts and funds, the TRF, CRS data and leaving the UK — the post-6 April 2025 frame.
A practical operating model for U.S. persons, families and founders managing worldwide tax reporting, FATCA, FBAR, CFC, PFIC, trusts and advisor workflow.
Comprehensive master guide to CFC (Controlled Foreign Company) rules: core regimes (Russia, US GILTI, UK TIOPA, EU ATAD) and mitigation strategies through tax residency planning.
How controlled foreign company (CFC) rules force tax residents to declare and pay tax on foreign income: filing duties, thresholds and cross-border wealth risks.
When a foreign trust or foundation becomes a CFC for a Russian tax resident: controlling person, notifications, undistributed profits, PIT and distributions.
Legal guide to pre-arrival UK tax planning for FIG, OWR, foreign companies, offshore funds, trusts, IHT and residence evidence.
Legal U.S. tax planning tools for Americans abroad: FEIE, foreign tax credit, totalization, entity classification, CFC/PFIC review, trusts, pre-immigration and expatriation planning.
A practical map for U.S. persons reporting foreign partnerships, disregarded entities, branches and transfers to foreign corporations on Forms 8865, 8858 and 926.
How U.S. persons report controlled foreign corporations, Subpart F income, GILTI, Form 5471, Form 8992, check-the-box planning and entity reporting.
British CFC rules: TIOPA 2010 Part 9A, gateway tests, charge calculation and interaction with Transfer of Assets Abroad and the FIG regime.
UAE tax residency (Cabinet Decision 85/2022): 183/90-day tests, 0% personal income tax, Golden Visa, TRC, DMTT 15% for large groups from 2025.
CFC rules under EU ATAD I (Articles 7–8): two approaches to income attribution and implementation across EU Member States for holding structures.