Investments into qualified Opportunity Zone Funds offer attractive tax benefits, while catalyzing capital inflows into economically distressed communities. However, prudence is necessary in evaluating these investment opportunities as they come to market. The tax benefits will not outweigh the negative consequences of a bad investment. While the pr...
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After looking at the potential pitfalls in Part 1 of this multipart series on the Tax Cuts and Jobs Act of 2017, we turn to Part 2: the Income Tax Opportunities. Regardless of your net worth, the temporary increase in the federal tax exemption has made possible certain strategies that could significantly reduce capital gains tax and allow...
The new year brings new tax-savings opportunities, including larger tax exemptions and exclusions. Here are some strategies and tips to consider in your tax planning this year, as well as the Federal Estate and Gift Tax Exemption/Exclusion Levels for Individuals and 2019 Federal Income Tax Brackets charts.
Taxpayers who have identified opportunities to take advantage of the increased gift tax exemption before 2026, but have been hesitant to do so because of the risk of clawback, now find themselves on firmer ground for moving forward with those plans. However, with all of the ways and means of using the exemption, what should they do ... and why? We ...
For insights on integrated wealth planning, this issue of The Advisor presents a view from the top with Joe Kahn, The New York Times Managing Editor, the impact of globalization 2.0, and the U.S. presidential election 2016 and the candidates’ tax platforms. Also in this issue are the best practices in providing age-appropriate transparency wh...
Asset protection follows the continuum of life’s events, reflecting the changes that individuals, families, careers, businesses and wealth undergo. Within the wealth spectrum, a simple way of thinking about asset protection strategies is from lower risk and simpler tactics to higher risk and more complex and sophisticated tactics. This approa...
The Foreign Account Tax Compliance Act (FATCA) is in full swing. Non-US financial institutions have completed reporting of US account holders for tax year 2014 and will soon begin compiling for their 2015 FATCA reports. Just as international families and their advisers are getting used to myriad requests for FATCA Form W-8 certification forms, more...
From a tax perspective, 2016 was a relatively calm year. But this relative calm shouldn't create complacency. Instead, it creates two significant opportunities for year-end planning. First, you can redirect the time and energy spent understanding new laws in years past toward a holistic look at your tax situation and plans for the future; you m...
Today’s PFTCs bear little resemblance to ‘private trust companies’ of the 1990s, the gestation era for the PFTC. The modern US PFTC also differs markedly from a third form of ‘private trust company’: its ‘offshore’ single family private trust company (OFTC). Limited federal taxation of foreign trusts and pr...
Most family offices that serve U.S. families are well aware that special planning considerations can arise when a U.S. citizen family member marries a noncitizen. Should the client’s estate plan be revised to incorporate a qualified domestic trust (QDOT) to ensure that assets passing to the surviving noncitizen spouse qualify for federal esta...
In early April 2016 files leaked from a large Panama-based law firm (known as the ‘Panama Papers’) brought to the attention of many the ways in which offshore companies and structures can be used to obscure the identity of beneficial owners, some of whom have used such entities to avoid paying tax in their country of tax residence. Now ...
Even though a trust may be established under the laws of a US state and have a US trust company serving as trustee (hereinafter a ‘US-based trust’), this does not mean that it is a US domestic trust for income tax purposes. If non-US persons make substantial decisions for the trust, the US-based trust will be classified as a foreign tru...
Private trust companies are not a new phenomenon. Rather, over the past 25 years, they have increased dramatically in number, with hundreds of major, family-controlled trust institutions now operating in the United States. This article addresses why the number of private trust companies has been growing; describes a typical private trust comp...
In this edition of Tax Topics, the focus is on the IRS release of the 2017 inflation-adjusted numbers, along with planning points to keep in mind for both year-end and in general. It also has the November 7520 rate and applicable federal mid-term rates.
Donald Trump’s election as the 45th President of the United States on November 8 is expected to bring changes to the tax laws for individuals and businesses. President-elect Trump had made tax reduction a centerpiece of his economic plans during his campaign, saying he would, among other things, propose lower and consolidated individual incom...