By Cynthia WuAbstractFollowing the Supreme Court’s holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the challenged tariffs, refund implementation has shifted from merits to mechanics: liquidation status, administrative capacity,

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 the challenged tariffs

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 be complex and challenging. Proper

Understanding Reverse 1031 Exchanges and the Risks of International Fund TransfersAt our law firm, we are helping clients navigate complex tax strategies, including 1031 exchanges, which allow taxpayers to defer capital gains taxes when

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 affect the scope

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 understanding of the

Foreign Grantor Trusts: Tax Implications for Grantors and BeneficiariesIntroductionA foreign grantor trust is a trust established outside the United States by a grantor (also known as a settlor or trustor) who may be

IntroductionWhen 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 bring the asset back

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 the termination of

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 critical requirement under