For families contemplating substantial charitable contributions, private foundations provide a structure to create a legacy of family charitable giving and remain a popular vehicle for charitably inclined families.While a private foundation may appeal to an individual for a variety of reasons; private foundations come with responsibilities. Prior t...
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On 18 March, the Russian Ministry of Finance published a draft law on anti-offshore measures (the Draft). This article by Withers LLP provides a thoughtful review of the Draft, which introduces three concepts:Controlled foreign companies rules (CFC)Russian tax residence for foreign companies based on tests of management and controlNew rules on taxa...
The sale of a business can be one of the most significant events for families of wealth. Often, family members have devoted substantial time and resources to building a successful enterprise.While the sale of the business may be viewed as the successful culmination of years of work, it may also cause concern for the owner, who feels there is not en...
As tax rates on the wealthy have begun to go up again, taxpayers have begun to take a second look at the few legitimate tax shelters still available, and this has renewed interest in investing through insurance dedicated funds (IDFs).This paper discusses two types of IDFs, Private Placement Variable Annuities (PPVA) and Private Placement Life Insur...
Every day we use smartphones, tablets, computers and other digital devices to access, transfer and store information, conduct financial transactions and operate many other aspects of our lives. Your digital assets include all of the digital devices you own, all data stored in them and on external servers, and all of your online user accounts. ...
Wealth management and tax planning, done right, require care and a thoughtful approach. Helping you be vigilant in these and all other aspects is the purpose of this guide, which walks you through the key concepts and approaches pertaining to tax planning, investing, charitable giving, estate and gift planning, business succession, family meetings,...
Whether a grantor is struggling with ensuring that a trust fulfills the intentions for which it was established or simply wants to sleep better at night knowing the trust assets will be managed and monitored effectively, the directed trust statute provides the flexibility and incentives needed to improve the long-term outcome.
In 2012, total charitable giving rose to $316 billion in the United States, driven by an $8 billion increase in gifts by individuals. This year, individual donations are likely to continue growing, spurred by tax changes, the improving economy and donor-friendly IRA rules. Here are five reasons why 2013 is a great year to give.
Selecting one’s home state as the situs may be a convenient or easy answer. However, the ability to implement a trust that may last forever, eliminate additional transfer taxes after funding and avoid state income taxes may provide the financial incentive to stray from home, or at least to consider it.
The allocation of receipts and disbursements between principal and interest are critical to the proper design and administration of trusts. Individuals creating trusts should have an appreciation and basic understanding of these concepts so the trusts will operate consistent with the settlors’ intentions and provide the intended benefits.
The American Taxpayer Relief Act of 2012 maintained the gift, estate and generation-skipping transfer taxes that were scheduled to sunset prior to 2013 and increased the exemptions for all three taxes to $5.25 million, making new or additional gifts to trusts a more attractive option in estate planning.
New Hampshire has a robust set of modern trust laws, which afford settlors broad flexibility and creativity in designing trusts well suited to their specific needs and wishes. Those laws facilitate the more efficient administration of trusts and, importantly, provide a high level of certainty concerning the rights, duties and powers of settlors, be...
For foreign entrepreneurs seeking to bring their businesses to the United States, the EB-5 Immigrant Investor Visa may seem like the perfect fit. Looks, however, can be deceiving. Green card holders are subject immediately to U.S. federal income tax on their worldwide income and informational reporting requirements for their foreign interests.
Without a full understanding of U.S. federal gift tax and income tax issues associated with a gift of money to a U.S. child, it is easy for a nonresident alien to convert what would have been a tax-free gift to taxable income. This guide outlines the most common gift-giving mistakes and how to avoid them.
Portability may have been viewed initially as the simple solution in situations in which there was the potential for loss of the applicable credit amount of the first spouse to die. While this is a valuable benefit, the impact and potential planning opportunities for portability go beyond this important but somewhat limited scope.