Research & publications
Original publications
Articles
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Implementing IEEPA Tariff Refunds After Learning Resources: The CIT’s Refund Orders, Administrative Feasibility, and the Unresolved “Final Liquidation” Gap
In Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections, Inc., the Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the executive branch to impose sweeping…
Cynthia Wu · 24 min read
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IEEPA Tariff Refunds After Learning Resources v. Trump: Legal Bases, Procedures, and Practical Strategy
By Cynthia Wu Marshall Olney Abstract In Learning Resources v. Trump, the Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose…
Cynthia Wu · 22 min read
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Estate Planning for Nonresident Aliens Who Own U.S. Real Estate: Federal Tax Issues
Estate Planning Strategies for Nonresident Aliens by: Cynthia Wu on Jan 24, 2026 Navigating the federal tax implications for nonresident aliens (NRAs) who own United States real estate can…
Cynthia Wu · 21 min read
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Understanding Reverse 1031 Exchanges and the Risks of International Fund Transfers
Understanding Reverse 1031 Exchanges and the Risks of International Fund Transfers At our law firm, we are helping clients navigate complex tax strategies, including 1031 exchanges, which allow taxpayers to defer…
Cynthia Wu · 6 min read
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NRA Grantor Trusts with U.S. Beneficiaries: Comparing Domestic and Foreign Structures
IntroductionNonresident aliens (NRAs) who wish to establish trusts for the benefit of U.S. beneficiaries often face complex U.S. tax considerations. The trust’s classification as either domestic or foreign can profoundly…
Cynthia Wu · 6 min read
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Understanding the Grantor Trust Rules Under IRC § 679: Key Considerations for Foreign Trusts
When it comes to estate planning and asset protection, foreign grantor trusts can be a powerful tool. However, navigating the complex U.S. tax rules surrounding these trusts requires a deep…
Cynthia Wu · 6 min read
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Foreign Grantor Trusts: Tax Implications for Grantors and Beneficiaries
Foreign Grantor Trusts: Tax Implications for Grantors and Beneficiaries Introduction A foreign grantor trust is a trust established outside the United States by a grantor (also known as a settlor…
Cynthia Wu · 6 min read
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Tax Consequences of a Dying Grantor Repurchasing Highly Appreciated Assets from a Foreign Irrevocable Grantor Trust
Introduction When a dying grantor (whether a Nonresident Alien (NRA) or a U.S. grantor) repurchases a highly appreciated asset from a foreign irrevocable grantor trust, the transaction can have significant tax implications. This strategy is often used to…
Cynthia Wu · 5 min read
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IRC § 684 (the deemed sale rule) on Foreign Grantor Trust
Upon the grantor’s death, the trust ceases to be a grantor trust, and IRC § 684 applies. This section triggers a deemed sale of the trust’s assets at fair market value (FMV) immediately before…
Cynthia Wu · 4 min read
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Understanding FBAR: A Guide for U.S. Taxpayers with Foreign Financial Accounts
At our law firm, we are committed to helping our clients navigate complex tax and legal obligations. One such obligation is the Report of Foreign Bank and Financial Accounts (FBAR), a…
Cynthia Wu · 5 min read
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