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)...
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 mont...
This report sheds light on a little-noticed wrinkle triggered by possible new 2013 rate changes that will make some taxpayers no longer subject to the Alternative Minimum Tax (AMT). Wealthy taxpayers currently paying AMT may see their effective marginal rates rise by as much as 12.5 percentage points under the law now scheduled to go into effect in...
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 subjec...
One of the potential benefi ts of wealth planning is the opportunity for families to have meaningful conversations about their hopes, dreams, legacy wishes, and more. These types of planning discussions can help to create family intimacy, and help build relationship capital for the future. In this white paper, Fidelity advisor Dr. Timothy G. Habber...
Just before midnight on January 1, 2013, the House of Representatives adopted the American Taxpayer Relief Act of 2012. There were few surprises except, perhaps, the extent to which numerous deduction and credit provisions remain intact. While the Act is expected to raise approximately $650 billion over the next 10 years, Congress must now contend ...
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, ...
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...
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, ...
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...
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 tr...
Proposals to reduce federal debt have largely missed the mark. That is certainly the case when it comes to suggestions to replace tax-exempt municipal bonds with taxable alternatives or federally subsidized tax credit options. These alternatives not only produce much less in revenue for the US Treasury than most assume, they also result in a loss o...
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.
This Educational Insights defines the most common types of trusts used in asset management and estate planning, and highlights their key features.
This Educational Insights discusses the unique estate tax and insurance implications of owning real estate in multiple jurisdictions.