The Tax Cuts and Jobs Act (the Act) was signed into law on December 22, 2017. The Act is
without a doubt the most impactful reform to the Internal Revenue Code since the tax reform of
1986. While it does not appear that the Act was specifically put forth to affect the private client
industry, it has done so in a significant way. The International Private Client Group of Benesch
has prepared this comprehensive Client Bulletin to identify and highlight the most relevant
considerations for non-U.S. families with connections to the United States.
Importantly, in light of the significant changes made by the Act, it is advisable that all of a nonU.S.
family’s investment structures be reviewed on a holistic basis to ensure not only that they
maintain the efficacy of the original planning, but also that they continue to be compliant with
any applicable U.S. reporting and/or tax obligations.