Resource Search

Non-U.S. families establishing succession planning structures rarely think about the U.S. generation-skipping transfer (GST) tax. Nevertheless, when a foreign trust becomes a U.S. domestic trust so that distributions can be made in a tax-efficient manner to the settlor’s U.S. grandchildren and more remote descendants, U.S. trustees or tax return preparers may raise questions about whether those distributions are subject to the GST tax. Advisers to these families should become familiar with the application of the GST tax rules in order to bring clarity to the situation.

A non-U.S. company's classification for U.S. tax purposes is important for Foreign Account Tax Compliance Act (FATCA) compliance and U.S. withholding tax reasons. Advisors to families with succession planning structures that include holding, operating, and other companies should determine the U.S. tax classification for each company in the structure and resulting compliance and tax implications.

Non-fungible Tokens (NFT) now represent a broad class of investments, from collectibles to more financial-type assets. As the applications advance, the existing consensus on the tax treatment of NFTs may change. While there is limited guidance from the IRS, there are considerations for creators and investors to keep in mind.

The Biden administration’s fiscal year 2023 budget blueprint that was released on March 28, and it consisted of a mix of familiar proposals and brand-new initiatives that reflect the President’s policy objectives. The familiar included calls for increasing the top corporate tax rate to 28% and the individual rate to 39.6%. Among the new proposals, the minimum tax on high-net-worth individuals has garnered considerable attention. These proposals, as well as others that have not been closely scrutinized, are described in this report.

Interest in collective investment trusts (CITs) as plan investment options is steadily accelerating. As part of this growing attention, CIT governance practices, and the policies and procedures banks and trust companies use to govern their CIT offerings, are emerging as factors that may warrant consideration by plan fiduciaries when making plan investment option decisions.

After more than a decade of record low interest rates, the combination of inflation and increasing interest rates has investors jittery; however, it also presents an opportunity for high-net-worth individuals to review and adjust their existing strategies for estate planning, business planning, financial planning, and wealth management.

A best-in-class family office tax function goes beyond preparing timely tax returns to drive tax strategy and reduce the overall income, gift, and estate tax burden across generations. Given the role taxes have on most families, it’s imperative for the family office to ensure it has the proper infrastructure and resources to understand, plan, and strategize from both the tax planning and compliance standpoint. Best practices are provided to help strengthen your family office’s tax capabilities.

Creating an enduring financial legacy becomes more challenging with each branch that is added to the family tree through marriage. With divorce rates at a high level, it is important for families to understand the wealth management considerations related to marriage and take a proactive approach to planning for changes to their family dynamics.

The IRS is increasing its audit of large partnerships and is increasingly scrutinizing the validity and deductibility of management fee arrangements. In the case, Aspro, Inc. v. Commissioner, it offers a warning to taxpayers, including private equity and venture capital funds seeking to establish similar arrangements with their portfolio companies. But perhaps more importantly, this case provides a roadmap for taxpayers to follow when structuring and documenting these arrangements.

Social media and other digital accounts have a life of their own. Managing them is one aspect of managing a deceased person's digital estate. Sometimes the problem is simply closing an account while other times, you hope to gain access to a loved one's accumulated photos, videos, or other important files. To help manage your digital accounts and plan ahead, know the rules governing Google accounts, Facebook, Instagram, LinkedIn, Twitter, and Dropbox.