An agreement was reached on 24 August between the UK Treasury and Swiss Federal Department of Finance regarding the treatment of Swiss accounts held by UK taxpayers. The agreement is due to be signed by both parties within the next few months at which stage the detailed terms will be issued. This briefing note summarises the outline of the agreement, which has been communicated by HMRC in advance of the full detail being available.
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Private split dollar can help freeze an estate, minimize gift taxes, provide access to cash values, and finance needed or desired insurance for family members. Properly structured, death benefits may be excluded from the insured's taxable estate and even passed to many successive generations if a dynasty-type trust is used.
Because of the uncertainty as to what the new congressional bipartisan joint committee will do, it is important that individuals who want to take advantage of existing estate planning techniques talk with their advisors now to find out whether such planning is appropriate based on their circumstances.
Changes in tax laws have made the long-term, or dynasty, trust a particularly attractive means to transfer wealth to multiple generations free of estate taxes. However, the expiration of certain exemptions in 2013 means individuals need to act soon to realize the maximum benefit of these trusts.
In this 2011 FOX Financial Executives Forum presentation, the president and CEO of the Policy and Taxation Group discusses up-to-the-minute legislative developments as well as the group’s ongoing lobbying efforts on behalf of wealthy owners.
Many individuals are wondering whether the IRS intends to use its new audit unit to develop tax enforcement cases. A former high-ranking executive with the IRS provides answers in this 2011 FOX Financial Executives Forum presentation.
Wealth owners have an 18-month window of opportunity to capitalize on gift, estate, and generation-skipping tax provisions of the 2010 Tax Act. In this session at the 2011 FOX Financial Executives Forum, a noted trusts and estates attorney recommends what to do now.
The financial risks associated with unplanned health care events need to be part of the financial planning process to guard against negative impacts to an investment portfolio or retirement income plan in the event of a catastrophe.
The lifetime credit shelter trust offers a way to lock in the benefits of the increased lifetime gift exemption of $5 million per person, as provided in the Tax Relief Act of 2010, without giving that much away immediately. One spouse can set up the tax-sheltered trust for the other without paying any gift tax, or they each can set up a trust of as much as $5 million for each other.
Modern dynasty trust laws, such as those in South Dakota, provide the settlor with the flexibility to deal with uncertainty while maintaining the benefits of intergenerational planning. Directed trusts, trust protectors, special purpose entities and other state statutory trust provisions provide the flexibility that has made the modern dynasty trust a popular planning tool for 2011 and beyond.