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International Tax Blog

Andrew Mitchel LLC is a law firm of international tax attorneys with extensive experience in international tax planning.

“Lump-Sum” Distributions From U.K. Pensions

Today we updated our flowchart analyzing the U.K.-U.S. Income Tax Treaty (the “Treaty”) as it applies to the taxation of U.S. and U.K. pensions.  There has been significant uncertainty regarding the definition of the term “lump-sum” in Article 17(2) of the Treaty.  The prior version the flowchart did not discuss which definition or definitions of the term “lump-sum” should be used.  We have updated the flowchart to include our view on which definitions should be used.  Below we provide a brief explanation of why we believe that the U.K.

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2018 Inflation Adjustments For Individuals In The International Tax Arena

This week the I.R.S. published Revenue Procedure 2017-58, setting forth inflation adjusted items for 2017. In the international arena, some of the important inflation adjustments include:

$165,000 — Code § 877(a)(2)(A) — The average annual net income tax that must be imposed for the five taxable years ending before the date of the loss of United States citizenship (or cessation of long-term permanent residency) for an individual to be considered a “covered expatriate” under Code § 877A(g)(1).

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Anticlimactic Discoveries

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is:

At the heart of the labyrinth, where one might expect to find, if not a Minotaur, then at least an old movie lion, we find high-basis, low-value assets (said to have spawned startling losses) and some B-grade films.

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