It’s official! The second to last Friday of the year, Uruguayan footballer Luis Suárez became the new addition of the InterMiami, painting in which he will meet again with his friend and former teammate at Barcelona FC, Lionel Messi. Inter’s number 9 shirt is now on sale and the whole world is waiting to see the reunion of Messi and Suárez on the pitch.
For some months there has been talk of this great pass, which finally came to fruition and left Uruguayans and Argentines happy He Inter Miami He will return to football activity in mid-January, so we will still have to wait a little. Meanwhile, I want to talk about what should be the next steps that the Uruguayan would have to take at the level of estate planning, taking into account tax issues.
As you know, every pass that a soccer player signs and every move has its consequences (I hope you have already learned it) and this case is no exception. Luis Suarez disembarks in USA, after his passage through the Guild, in Brazil, and he faces a new stage in his career and, almost as important as that, a new tax regime.
What is it about? In the tax system of USA There are two fundamental questions to take into account for anyone and, especially, for a soccer star like Suarez:
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The global income (income tax): Through this tax, people pay for their profits, regardless of where in the world they are generated. That is, it does not matter whether these profits originate in USA or in any other corner of the world, the income tax applies the same.
- Capital gains tax: This tribute implies that Luis Suarez You will pay taxes on the income you have from your salary. Miami as a soccer player, but also for his advertising contracts or for the capital gains generated by his investments. Are there strategies to differentiate what is capital gains? Yes, but the reality is that Suárez is not going to be able to reduce the final amount to be paid too much.
A restructuring due to the high inheritance tax
The great asset structuring What the Uruguayan could do upon his arrival in Miami has to do with the inheritance tax: in USA The inheritance tax is extremely high (40% above the non-taxable minimum, which changes depending on whether or not the deceased is a North American resident). In this way, all assets that are not considered capital gains will be subject to inheritance tax.
So what you should do “the gunfighter” Suárez before settling in USA It is structuring your assets in such a way that most of your assets remain outside the country, for inheritance purposes. Of course, there are many ways to achieve this with proper advice, but generally this is achieved through a irrevocable trust.
One fact that is good to keep in mind is that, if Suárez (in this case) had created this trust five years ago, he would now not pay capital gains or income tax, because that is what North American legislation establishes. On the other hand, if the trust is made today, the footballer will have to pay both taxes.
This is, broadly speaking, the scenario in terms of estate planning that faces Luis Suarez with his arrival at Inter Miami. As you can see, beyond the good news for the football world, there are many issues to address. Of course, as I always say, the ideal is that each step be accompanied by a Professional advice.
*Martin Litwak, expert lawyer in taxation and international estate planning.
Source: Ambito