Our Services
We understand that an advisory firm must match top-quality technical interpretation with an understanding of the operational implications in order to deliver advice that can be implemented by the client efficiently and without undue disruption
FATCA/QIAutomatic exchange of account and payment information for US Persons and non-US Persons receiving US income
Other US International, Corporate, Trust & Partnership Tax MattersA variety of tax advisory services focused on cross-border payment flows and asset holdings for US Persons and non-US Persons with US assets, including US income and estate taxation, with an eye on the current plans for a proposed global corporate tax minimum and the consequences in Switzerland and elsewhere from the 2017 TCJA and coming US tax reforms
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OECD CRS Automatic exchange of financial account information by banks and other financial intermediaries
CARF / DAC8 / Crypto Asset Broker ReportingIncreased tax and regulation of digital assets, including incoming inclusion into reporting regimes, such as CRS per OECD's CARF and EU's DAC8
EU DAC6 & OECD MDRsDisclosure rules for service providers party to cross-border transactions displaying "aggressive" tax attributes |
The Corporate Transparency Act (BO registry) The new federal company owner registry compels US corporations, LLCs and similar entities to disclose information on, primarily, their Beneficial Owner(s) via a non-public portal.
US §871(m)Withholding and reporting on non-US investors on payments from derivative instruments with underlying US equities
US §864(c)(8) & §1446(f)Withholding and reporting on payments to on non-US investors from US PTPs, private equity and other funds holding active US companies |
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Prior to establishing his own advisory firm, Paul Foster Millen (NYU School of Law, J.D. '05, LL.M in Tax '18), the founder and principal of Millen Tax & Legal GmbH, serves as the lead advisor to Swiss banks, derivative product issuers, trust companies and single family offices on an array of US-related and cross-border tax and regulatory topics.
Millen Tax & Legal GmbH was established under the applicable corporate formation laws of the Canton of Zurich in Switzerland and registered by the cantonal corporate registrar (Handelsregistraramt), effective as of 9 February 2017. |
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