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Taxing bodies in the UK and the United States are taking a closer look at debt-related strategies by hedge funds that are now tax exempt. And as investment strategies become more diverse, this interest by fiscal authorities can only be expected to increase. This paper from PricewaterhouseCoopers explores the potential ramifications for global hedge...

A health and education exclusion trust may offer a way to preserve assets for younger family members and avoid harsh generation-skipping taxes, while still contributing to charity. In this article, Mela Garber of Anchin, Block and Anchin explains how a HEET can be a useful and effective estate planning tool that benefits family and a designated cha...

A health and education exclusion trust may offer a way to preserve assets for younger family members and avoid harsh generation-skipping taxes, while still contributing to charity. In this article, Mela Garber of Anchin, Block and Anchin explains how a HEET can be a useful and effective estate planning tool that benefits family and a designated cha...

By thinking ahead and paying a long-term capital gain today, an investor can derive a net tax benefit in future years. This research brief from Parametric Portfolio Associates explores the tax-management strategy of realizing such gains in a portfolio of equities and quantifies how much this can add to after-tax performance. The authors evaluate th...

This paper will examine ways to lessen six of the greatest risks to preserving and enjoying multigenerational wealth. These six risks are: concentrating your assets, overspending, overusing leverage, poor tax planning, not attending to liabilities, ignoring family governance

The IRS revenue ruling regarding the deductibility of management fees by limited partners of partnerships that invest in other partnerships tends to target funds of funds. WTAS believes this ruling may have a wider effect on any tiered partnership structure.

Two notices from Withers Worldwide discuss changes to U.S. tax rules in the deferred remuneration area that take effect on 1 January 2009. These rules (found in Sections 409A and 457A of the U.S. tax code) target deferred payments that do not satisfy complex technical requirements, imposing a compliance burden on non-U.S. as well as U.S. employers....

A limited liability company may seem like the best way to structure private aircraft ownership, organizing finances while shielding other assets from liability, but think again, says Gary Horowitz of Wiley Rein. Using an LLC can lead to a huge tax liability, potential fines by the Federal Aviation Administration and increased personal liability. Th...

With short-term interest rates currently near zero, this may be a good time to consider using intra-family loans, grantor retained annuity trusts and sales to intentionally defective grantor trusts.

By limiting the deductibility of investment-managing expenses by trusts, the Supreme Court's decision in the Knight case increases the taxes on trusts that use professional investment managers. This article by Richard LeVine of Withers Bergman examines the ruling and notes the need for innovative relationships between trusts and assets managers to ...

Donating appreciated securities to charities may provide tax advantages over making cash donations by reducing capital gains taxes. This report from Fidelity Investments explores the issue, providing assistance in calculating tax savings and explaining how a donor advised fund can reduce paperwork to make these donations easier.

Private trust companies can protect and enhance a family's wealth, but the ownership options need to be weighed carefully. In this article, Michael Stanford-Tuck of Bermuda-based Appleby Global discusses such choices as the non-charitable purpose trust, the Cayman Islands' STAR trust and the British Virgin Islands' VISTA trust.

Pre-nuptial agreements and marriage agreements are not binding under English law, leaving the details of divorce settlements largely in the hands of judges. But decisions rendered in the past five years show that judges are now taking pre-nups more seriously. This article from Withers shows how an appeals court has interpreted the importance of a p...

An inherited fortune may come with strings attached as wealthy families make a college education or job experience a condition of inheritance. About 60 percent of families with more than $10 million in assets place stipulations like these, according to a report on attaining and retaining wealth from Barclays Wealth. The report also discusses the im...

The answer to whether to establish a Roth account or to roll over a traditional retirement account to a Roth is not always obvious because of the upfront tax cost associated with the Roth. Whether an individual reaps an offsetting benefit will depend on how long money remains in the account, the tax rates in effect when it is withdrawn and how the ...