The Internal Revenue Service has issued long-anticipated final Treasury Regulations delineating which expenses of an estate or a non-grantor trust are not subject to the 2% floor on miscellaneous itemized deductions.
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Policy and Taxation Group commissioned important research by leading pollster Frank Luntz to understand why resentment toward high net worth individuals has increased so much in recent years and what the impact of heightened class conflict has been and will be on the future of the fight for estate tax relief. As Policy and Taxation Group has remained exclusively focused on the estate tax fight, several PATG families launched a separate effort called Each American Dream to continue this valuable research and reduce the stigmatization of success in the economic debate.
Delaware has long been a jurisdiction of choice for grantors of trusts—for generations, the state has built a trust-friendly body of legislation and has supported its laws with a knowledgeable and effective court system. In this package of white papers, our wealth strategies experts explain the benefits and considerations of Delaware trusts.
Since 2006, New Hampshire has permitted the formation of family trust companies. This paper summarizes the advantages of creating family trust companies in a favorable site such as New Hampshire.
New Hampshire’s directed trust statutes provide families with maximum flexibility and control in the creation and ongoing administration of trusts. This paper explores the benefits of directed trusts and illustrated a typical NH directed trust structure.
South Dakota’s favorable tax, trust and asset protection laws make it one of the top domestic asset protection jurisdictions. The January 2014 issue of Trusts & Estates magazine ranks South Dakota #1 in all categories including asset protection laws. In fact, it is the only state that ranked #1 across all categories (i.e., tax, trust laws, private trust companies, and asset protection). Consequently, these favorable laws combined with SDTC’s experience make South Dakota the jurisdiction of choice for many wealthy clients.
South Dakota is the leading bank asset jurisdiction in the United States, according to the FDIC. As the leading trust, asset protection, privacy and favorable tax jurisdiction, South Dakota has attracted many wealthy families to establish trusts in South Dakota without having to live, visit or even fly over the state.
It’s the Fourth Quarter for corporate trustees who are burdened with the decision of how to implement the final regulations under Section 67 issued by the IRS last May. These regulations, govern the costs incurred by trusts and estates that are subject to the 2-percent floor on miscellaneous itemized deductions under Section 67. The regulations apply to tax years beginning on or after May 9, 2014, and thus for existing trusts using a calendar year, 2015 will be the first tax year governed by the new regulations.
The PFTC represents an elegant evolution of the family office by solidifying the role of the family in managing all of the family assets (more than just trust assets) and implementing its strategic plan. In this session, expert advisors and a family office executive share how to successfully integrate the PFTC with the family enterprise.Attendees will learn:
PFTCs provide significant flexibility with respect to investment management. The governance models afforded under PFTCs allow families to carefully craft the role of investment management, from the what, to the who, to the how. Modern trust laws in select states will allow you to create this flexibility through PFTCs, or for those less inclined, through a directed trustee arrangement.Attendees will learn: