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It has been more than three years since the enactment of Sec. 877A, which introduced a mark-to-market tax on U.S. persons expatriating on or after June 16, 2008. Its introduction has impacted the decisions of many to attain a green card or citizenship. It can be costly for wealthy individuals to become a covered expatriate (as described below) and, consequently, taking steps to avoid becoming a covered expatriate has become a fundamental part of pre-immigration planning.

Time is of the essence. Significant wealth planning opportunities are set to expire at the end of 2012. It is critical for wealthy families that have taken a wait and see approach to the future of gift and estate taxes to formulate a plan now. Developing and implementing well thought out and properly structured wealth planning strategies takes months, not weeks.

In the past year, the IRS sharply increased the number of returns it audited, particularly those of high-income earners. According to a government official, this is an effort “to build public confidence in the tax system, encouraging voluntary compliance” and to make sure that both the low end and high end of the income scale are subject to the same rules. This paper reviews recent trends on how the IRS selects individuals for audits and how to be prepared for one.

Choosing an executor is one of the most important decisions individuals make when preparing their will. This white paper explains the executor’s role and offers insights into how you might choose an executor for your estate.

Americans are likely to see tax simplification and a more efficient process in 2013. Under tax simplification, there will likely be fewer deductions, but tax rates will be lower. However, the actual outcome of various tax initiatives will be very unpredictable regardless of what the candidates say during the campaign.

An integrated approach to estate planning and wealth management can achieve a greater likelihood of successful wealth transfer and minimization of transfer taxes. Wealthy clients who embrace this approach can hope to realize their wealth transfer goals early enough in their lifetimes to obviate reliance on transfers at death at significant extra transfer tax cost.

With the looming December 31 expiration of the Bush tax cuts, the threat of sequestration, and the need to raise the debt ceiling in January, neither Democrats nor Republicans will want to face the consequences of inaction and/or no agreement. The nature of these issues and the convergence of interests and deadlines lead us to predict a deal that fully or substantially avoids sequestration, partially extends the Bush tax cuts, and raises the debt ceiling.

Reporting requirements for capital asset sales have changed, and the IRS is now in a better position to verify and track your activity. This article explains the IRS’ equation: verify + track + match data + audit = increased tax collection.