Victor Jaramillo Addresses Dual Residency Issues at ABA U.S. and Europe Tax Practice Trends Conference
This panel will shed light dual tax residency related tax planning issues and traps for the unwary. Issues can arise in an income tax, estate, inheritance or gift tax context. Initially, we will briefly consider the residence rules of seven countries (France, Italy, Malta, Spain, Switzerland, UK and U.S) and its treaty tie-breaker rules. Then, we will discuss selected issues in an “inbound from the U.S.” and “outbound from the U.S.” context with reference to the seven countries.