Search Results

On June 26, 2013, the Supreme Court of the United States issued two groundbreaking opinions regarding same-sex marriage. The rulings will substantially impact financial and estate planning for same-sex couples living in jurisdictions that recognize same-sex marriage. Now is a critical time for same-sex couples, regardless of their legal status, to ...

Wealth planning for same-sex married couples presents a host of challenges, and the landscape is fluid. Congress passed the Defense of Marriage Act (DOMA) in 1996, and President Bill Clinton signed the act into law the same year. The bill had two main functions. First, DOMA prevented the federal government from recognizing same-sex marriages for th...

This paper examines the advantages and disadvantages of four compliance options available to U.S. taxpayers who have not reported all of their non-U.S. income or who have not complied with all of the various reporting requirements applicable to non-U.S. income and assets.

This article addresses some of the most important legal and tax issues the real property professional needs to know when representing foreign investors in the United States, as every aspect of involvement is different from those of a domestic purchaser.

The decision to immigrate to the United States for a wealthy individual or family has serious income and wealth transfer tax considerations. Arranging one’s personal, financial and business affairs prior to moving to the United States through proper pre-residency tax and estate planning is essential in order to avoid a myriad of unwelcomed is...

Many wealthy families envision keeping a shared property in the family as a means of building family unity, harmony and legacy. A number of notable families have been successful at this, but many others find the reality creates the opposite of their intention.

Wealthy individuals need to play an active role in their wealth management, asking advisors the right questions and reviewing their answers regularly. This requires a solid understanding of wealth management principles and how to apply them in a variety of areas, ranging from personal tax planning to the transfer of a business.

The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the fourth in a series of deadline extensions for certain required filings in relation to foreign assets. FinCEN Notice 2012-2 extends the filing date for some filers of Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts (FBAR),&rdqu...

A Private Family Trust Company (PFTC) is typically a family owned LLC (i.e. pass through entity or corporation), authorized by a state’s Division of Banking to be a PFTC and serve as the trustee for the family’s trusts. This article outlines key considerations in establishing a PFTC and two alternatives: a Directed Trust and a Directed ...

Nearly all states have “delegated” trust statutes, but only a few states, such as South Dakota, have “directed” trust statutes, which provide families with maximum flexibility and control regarding a trust’s asset allocation, diversification, investment management and distributions.

This guide covers wealth management and tax planning strategies to consider before year-end and into 2012. Topics include tax management, wealth transfer planning, education funding, philanthropy, retirement, liabilities management, insurance, business owner issues, tax implications of health care reform, and building a strategic plan.

The authors summarize the history of the IRS' voluntary disclosure programs to date and conclude that, indeed, it is still possible for a U.S. person to become U.S. tax compliant and avoid criminal prosecution by making a voluntary disclosure.

After many months of heated debate, Congress passed the American Taxpayer Relief Act of 2012 (“ATRA”), which President Obama signed into law on January 2, 2013, averting the tax side of the so-called “fiscal cliff”. ATRA permanently extends the middle-class tax cuts, raises income tax rates on the wealthiest and, hopefully, ...

After briefly plunging over the “fiscal cliff” – the combination of tax increases and spending cuts that automatically came into effect on January 1, 2013 – Congress quickly passed the American Taxpayer Relief Act of 2012 (the “Act”), which has now been signed into law by President Obama. This white paper summarizes those aspects of the Act that Wi...

Keeping in mind that permanence and certainty are relative terms when it comes to tax legislation, Congress has finally provided a platform that allows for longer-term planning than we have had in the past. Although the American Taxpayer Relief Act of 2012 was passed too late to provide the certainty that is so important for year-end tax planning, ...