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Simon Beck

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Simon Beck is a partner and chair of the North America Wealth Management Group at Baker McKenzie's New York office. Simon is an international tax and trust lawyer with vast experience working in the world's trust and financial centers. He has also practiced in Miami, London, Monte Carlo and Madrid, and was head of Legal, Compliance and Trust & Fiduciary Services for Coutts, one of the world’s leading private banking institutions, prior to joining Baker McKenzie. Simon lectures regularly on trust, financial service and compliance issues at global wealth management and international trust and estate planning conferences around the world.

On 23 July 2020, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) published final regulations under Section 951A providing guidance with respect to the high-tax exception, which excepts certain ‘high-taxed’ income from being otherwise taxed as “Global Intangible Low-Tax Income” (“GILTI”). The final regulations maintain the same foreign tax rate threshold to be eligible for a high-taxed income exclusion while simultaneously modifying operational rules that may affect a U.S. individual’s decision to pursue the exclusion. In conjunction with these final regulations, Treasury and the IRS issued new proposed regulations conforming aspects of the Subpart F high-tax exception with the newly finalized GILTI high-tax exception, and providing for a single high-tax exception election under Section 954(b)(4). 

Click here to request the latest edition of this newsletter.  Feature Malaysia: Wealth management and tax planning in the wake of COVID-19 Case Summaries Brazil Private Letter Ruling No. 41 of 31 March 2020 — tax treatment of trust distributions to Brazilian beneficiaries France Wealth tax — The refusal to…

In brief Up until now, the medical exception to the substantial presence test has been limited only to medical conditions arising while such individual was present in the United States. During this unprecedented time, with countries closing their borders, global travel limited and persons stranded in countries not their own,…

Federal Tax and Payment Deadline has been extended. The IRS, through a series of IRS Notices, has delayed certain tax return filings and payments due April 15, 2020 through July 15, 2020. Taxpayers (individuals and businesses, as well as trusts, estates, partnerships, corporations) were granted an extension of time to…