International Estate Planning: Estate Structuring for Australians who are US Citizens or Green Card Holders
Consider this scenario: You and your spouse are Australians with US citizenship or green cards, and intend to live in the US indefinitely.... Read more
Capital Gains and Non-Resident Beneficiaries: It’s Bad News Again as Martin Holdings Confirms Greensill
On August 18th, 2020, the Federal Court of Australia handed down its decision in N & M Martin Holdings Pty Ltd v Commissioner... Read more
Structuring Australian Inheritances for US Citizens and Green Card Holders – Testator Considerations
How should your estate be structured if one of your children lives in the US and intends to do so indefinitely? This is an... Read more
LLC Series: Selling or Converting an LLC interest – the Australian Tax Implications: Hybrid Entities, Subdivision 122-B, and the Impact of Burton
For Australian tax purposes, an LLC is a “foreign hybrid company” and treated as a partnership for Australian tax purposes if it satisfies... Read more
LLC Series: Selling or Converting an LLC Interest – the US Tax Implications: Partnerships, “Effectively Connected Income” and the US Non-Recognition Rules
An LLC is a popular entity for Australians investing, or carrying on business, in the US. What happens if your business has matured... Read more
