Search Results

In early April 2016 files leaked from a large Panama-based law firm (known as the ‘Panama Papers’) brought to the attention of many the ways in which offshore companies and structures can be used to obscure the identity of beneficial owners, some of whom have used such entities to avoid paying tax in their country of tax residence. Now ...

Most family offices that serve U.S. families are well aware that special planning considerations can arise when a U.S. citizen family member marries a noncitizen. Should the client’s estate plan be revised to incorporate a qualified domestic trust (QDOT) to ensure that assets passing to the surviving noncitizen spouse qualify for federal esta...

Today’s PFTCs bear little resemblance to ‘private trust companies’ of the 1990s, the gestation era for the PFTC. The modern US PFTC also differs markedly from a third form of ‘private trust company’: its ‘offshore’ single family private trust company (OFTC). Limited federal taxation of foreign trusts and pr...

From a tax perspective, 2016 was a relatively calm year. But this relative calm shouldn't create complacency. Instead, it creates two significant opportunities for year-end planning. First, you can redirect the time and energy spent understanding new laws in years past toward a holistic look at your tax situation and plans for the future; you m...

The Foreign Account Tax Compliance Act (FATCA) is in full swing. Non-US financial institutions have completed reporting of US account holders for tax year 2014 and will soon begin compiling for their 2015 FATCA reports. Just as international families and their advisers are getting used to myriad requests for FATCA Form W-8 certification forms, more...

Asset protection follows the continuum of life’s events, reflecting the changes that individuals, families, careers, businesses and wealth undergo. Within the wealth spectrum, a simple way of thinking about asset protection strategies is from lower risk and simpler tactics to higher risk and more complex and sophisticated tactics. This approa...

For insights on integrated wealth planning, this issue of The Advisor presents a view from the top with Joe Kahn, The New York Times Managing Editor, the impact of globalization 2.0, and the U.S. presidential election 2016 and the candidates’ tax platforms. Also in this issue are the best practices in providing age-appropriate transparency wh...

Lifetime gift planning can include gift to spouse, annual exclusion gift, UTMA accounts, 2503(c) Trust, funded Crummey trust, 529 plans, payment of tuition and medical expenses, gift to irrevocable life insurance trust, and gifts to qualified personal residence trust (QPRT). When it comes to the basic estate and gift planning, it helps to have an a...

Asset ownership, insurance, irrevocable trust, limited liability entities, and asset protection trusts are key vehicles when it comes to protecting your assets. Having an overview of what is protected under these vehicles—including the costs, administrative considerations, income tax treatment, and the estate and gift treatment—provides...

When evaluating possible estate planning counsel, there are many variables to consider such as educational background and professional experience, skills, and review process. To help you determine if the prospective attorney is truly qualified to help you, there are ten key questions to ask and guidelines to follow.

Using a New Hampshire trust, a settlor can eliminate a trustee’s reporting and disclosure requirements if he or she wishes to withhold knowledge of the trust’s existence, its terms, or the details of its holdings. Many settlors are turning to New Hampshire to create “quiet” or “silent” trusts under which the trus...

There are a lot of questions surrounding whether snowbirds and others can shift his or her residency to a lower or no tax state such as Florida, Nevada or Texas, while still maintaining a home in Illinois. However, in light of Illinois’ current economic state and future debt obligations, it is hard for many Illinois residents and businesses n...

The American Tax Payer Relief Act of 2012 (ATRA) was passed on New Year’s Day 2013, and established the first permanentset of estate, gift and generation skipping transfer (GST) tax provisions in 12 years. Each year, the administration puts forth tax proposals that may change the current law. This article provides a quick summary of sev...

In 2013, the International Consortium of Investigative Journalists (ICIJ), a nonprofit group of reporters, shattered the long-held view that offshore bank secrecy was impenetrable. The group had received massive leaks detailing individual offshore bank accounts, which they shared with the public on their website. This was the first of hundreds...

President Obama on January 20, 2015, used his sixth State of the Union address to lay out his tax policy agenda to the new Republican-controlled 114th Congress. In a subsequent speech, Treasury Secretary Jack Lew reaffirmed the Administration's tax reform goals that were first outlined in a 2012 'framework' for business tax reform. Mean...