This paper examines the advantages and disadvantages of four compliance options available to U.S. taxpayers who have not reported all of their non-U.S. income or who have not complied with all of the various reporting requirements applicable to non-U.S. income and assets.
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On June 26, 2013, the Supreme Court of the United States issued two groundbreaking opinions regarding same-sex marriage. The rulings will substantially impact financial and estate planning for same-sex couples living in jurisdictions that recognize same-sex marriage. Now is a critical time for same-sex couples, regardless of their legal status, to review their estate plans to ensure that they are optimally structured.
Wealth planning for same-sex married couples presents a host of challenges, and the landscape is fluid. Congress passed the Defense of Marriage Act (DOMA) in 1996, and President Bill Clinton signed the act into law the same year. The bill had two main functions. First, DOMA prevented the federal government from recognizing same-sex marriages for the purposes of federal laws or programs. Second, DOMA absolved individual states from having to legally acknowledge the relationships of gay and lesbian couples who were married in another state.
This article addresses some of the most important legal and tax issues the real property professional needs to know when representing foreign investors in the United States, as every aspect of involvement is different from those of a domestic purchaser.
Wealthy individuals need to play an active role in their wealth management, asking advisors the right questions and reviewing their answers regularly. This requires a solid understanding of wealth management principles and how to apply them in a variety of areas, ranging from personal tax planning to the transfer of a business.
Many wealthy families envision keeping a shared property in the family as a means of building family unity, harmony and legacy. A number of notable families have been successful at this, but many others find the reality creates the opposite of their intention.
David Friedman, President of WealthX, will share his firm's research on the private business marketplace, identifying its size and ownership by industry type. David will compare US ownership trends with patterns found in other parts of the world and how transfer taxes impact business structures. He will help us evaluate the importance of private capital, the implications of worldwide shifts in private capital, and what these shift may mean for the global economy.
The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the fourth in a series of deadline extensions for certain required filings in relation to foreign assets. FinCEN Notice 2012-2 extends the filing date for some filers of Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts (FBAR),” from June 30, 2013, to June 30, 2014. This article reviews FBAR reporting requirements, who is exempt from filing an FBAR, and who is affected by the extended deadline.
After many months of heated debate, Congress passed the American Taxpayer Relief Act of 2012 (“ATRA”), which President Obama signed into law on January 2, 2013, averting the tax side of the so-called “fiscal cliff”. ATRA permanently extends the middle-class tax cuts, raises income tax rates on the wealthiest and, hopefully, will bolster economic growth.
Just before midnight on January 1, 2013, the House of Representatives adopted the American Taxpayer Relief Act of 2012. There were few surprises except, perhaps, the extent to which numerous deduction and credit provisions remain intact. While the Act is expected to raise approximately $650 billion over the next 10 years, Congress must now contend with a February deadline to address spending reductions and the debt ceiling.