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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 agreemen...

Increased tax exemptions, continued availability of valuation discounts, historically low interest rates and depressed asset values have created a perfect storm for families interested in preserving their wealth. However, current opportunities may begin being eliminated as early as January 2012.

Among the items on the list are basic tax-free gift opportunities, larger exempt gifts, tax-free transfers to credit shelters and family trusts, IRAs and retirement benefits, charitable contributions from IRAs, low interest rates related to leveraged gifting opportunities, decanting and creative planning with irrevocable trusts, and family C corpor...

Recently the IRS released proposed regulations under Chapter 14 of the Internal Revenue Code that would severely limit—if not eliminate—the application of valuation discounts, including lack of marketability and minority discounts, to interests in closely held family entities for gift, estate, and generation-skipping transfer tax purpos...

The federal government proposed sweeping new tax rules earlier this month that would dramatically affect family businesses, investment partnerships and other entities. These rules, which could become final and binding as early as the end of 2016, would artificially inflate the value of interests in family entities for gift and estate tax purposes. ...

For years, owners of family-controlled companies have taken advantage of applicable valuation discounts to advance their objectives in transferring wealth and company ownership to future generations in a tax efficient manner. On August 2, the Treasury Department issued proposed regulations under Internal Revenue Code Section 2704 to curb the use of...

The metaphorical glass slipper represents the combined interpersonal dynamics of your family and loved ones, your individual passions, goals, hopes and dreams, along with the complexity of your family’s estate plan. When combining the characteristics of your family with the complexity of your estate plan, the result is a unique dynamic with s...

The death of a loved one is a difficult and emotional time for a family. There is often additional stress if you are appointed as the executor of the will and trustee of your family’s trusts, especially if the deceased had been the sole manager of substantial family assets and wealth. For an untrained person, it can be a daunting role. For these re...

After 17 years of declining or fairly constant tax rates, investors face a changing environment of much higher tax rates on investment income starting in 2013. This brief from BNY Mellon Wealth Management details the coming changes in taxation and offers strategies for greater tax efficiency for business owners, investors and corporate executives.

Intra-family loans can provide a low-risk way to achieve estate planning objectives in a volatile economy, but these loans can result in unexpected taxable income or gift taxes. In addition, some debt attributes can pose valuation challenges. Stout Risius Ross discusses valuation concepts and other important attributes to consider in structuring in...

A short article from TaylorWessing highlights the benefits of a Liechtenstein Disclosure Facility, including a shorter taxable period, lesser tax penalties and the guarantee of no criminal prosecution than would be otherwise available within the UK tax regime. For an individual eligible for the LDF, in the great majority of cases the LDF will offer...

With the announcement of a Conservative-Liberal Democrat coalition, the uncertainty as to who will govern the UK is over. However, what does this mean for taxpayers? Withers Worldwide looks at the likely changes under the new administration and the implications for taxpayers.

With the IRS intensifying its focus on taxpayer non-compliance, ultra-wealthy individuals are wise to take steps now to reduce the likelihood of an audit and ensure they are fully prepared if one should occur in the future. A new white paper from HUB International offers some guidance for proactive taxpayers.

With estate tax repeal less likely, grantor trusts are gaining attention as a way to optimize existing tax exemptions. Because grantor trusts offer income tax and estate tax benefits, they also can be a powerful tool for removing assets from a taxable estate. This article from Atlantic Trust Private Wealth Management explains the types of trusts, h...

Experiencing an investment loss is bad enough, but that situation is even worse when those losses cannot be used to reduce tax liability. Rothstein Kass explores the recent Garnett decision by the U.S. Tax Court, which broadened the rules used to determine whether participation in a business activity can be considered passive activity. This designa...