Droit Fiscal Américain
Legal Challenge Filed Against Trump Administration’s Global Tariffs
Twenty-four U.S. states have filed suit in the Court of International Trade challenging global tariffs imposed under Section 122 of the Trade Act of 1974.
Implementing the Supreme Court’s Decision: The Court of International Trade Orders Removal of IEEPA Tariffs
The U.S. Court of International Trade ordered CBP to liquidate certain import entries without IEEPA tariffs following the Supreme Court’s decision invalidating those duties. The ruling may lead to significant refunds for importers and raises key questions for customs litigation.
U.S. Exit Tax and Swiss Occupational Pension Plans (LPP)
Renouncing U.S. citizenship may trigger significant Exit Tax exposure, particularly on Swiss LPP pension capital. Understanding IRC §877A and Covered Expatriate rules is essential for international wealth planning.
U.S. Estate Tax and Prior Gifts: A Critical Risk in International Estate Planning
How prior lifetime gifts can impact U.S. Estate Tax calculations and treaty credit planning for European investors and family offices.
