Taxing bodies in the UK and the United States are taking a closer look at debt-related strategies by hedge funds that are now tax exempt. And as investment strategies become more diverse, this interest by fiscal authorities can only be expected to increase. This paper from PricewaterhouseCoopers explores the potential ramifications for global hedge...
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This paper will examine ways to lessen six of the greatest risks to preserving and enjoying multigenerational wealth. These six risks are: concentrating your assets, overspending, overusing leverage, poor tax planning, not attending to liabilities, ignoring family governance
By thinking ahead and paying a long-term capital gain today, an investor can derive a net tax benefit in future years. This research brief from Parametric Portfolio Associates explores the tax-management strategy of realizing such gains in a portfolio of equities and quantifies how much this can add to after-tax performance. The authors evaluate th...
A health and education exclusion trust may offer a way to preserve assets for younger family members and avoid harsh generation-skipping taxes, while still contributing to charity. In this article, Mela Garber of Anchin, Block and Anchin explains how a HEET can be a useful and effective estate planning tool that benefits family and a designated cha...
New tax regulations from the Internal Revenue Service should have companies reviewing their business aircraft ownership structure and operations, according to a report from the law firm Wiley Rein. Depending on how this structure is set up, companies may find themselves subject to federal excise taxes on air transportation beginning January 1.
A limited liability company may seem like the best way to structure private aircraft ownership, organizing finances while shielding other assets from liability, but think again, says Gary Horowitz of Wiley Rein. Using an LLC can lead to a huge tax liability, potential fines by the Federal Aviation Administration and increased personal liability. Th...
Two notices from Withers Worldwide discuss changes to U.S. tax rules in the deferred remuneration area that take effect on 1 January 2009. These rules (found in Sections 409A and 457A of the U.S. tax code) target deferred payments that do not satisfy complex technical requirements, imposing a compliance burden on non-U.S. as well as U.S. employers....
Changes in tax law on estates and gifts provide lower valuations, which makes this a good time to focus on estate planning. An advisory from Rothstein Kass offers suggestions on beginning the process as well as pointers on taking advantage of current and proposed tax laws so that families can transfer as large an estate as possible to future genera...
The new administration has turned 2009 into a year of changes in state, gift and income tax laws – and more changes are expected before the year ends. Credit Suisse Securities (USA) provides an update on the extension of the IRA charitable rollover as well as changes to the gift tax annual exclusion, the generation-skipping transfer tax, and family...
The Internal Revenue Service has increased its scrutiny of multinational corporations and ultra-wealthy investors who try to minimize their taxes inappropriately through foreign investments. PricewaterhouseCoopers offers a checklist that U.S. investors can use to make sure they comply with international tax-reporting requirements.
Pre-nuptial agreements and marriage agreements are not binding under English law, leaving the details of divorce settlements largely in the hands of judges. But decisions rendered in the past five years show that judges are now taking pre-nups more seriously. This article from Withers shows how an appeals court has interpreted the importance of a p...
Private trust companies can protect and enhance a family's wealth, but the ownership options need to be weighed carefully. In this article, Michael Stanford-Tuck of Bermuda-based Appleby Global discusses such choices as the non-charitable purpose trust, the Cayman Islands' STAR trust and the British Virgin Islands' VISTA trust.
Donating appreciated securities to charities may provide tax advantages over making cash donations by reducing capital gains taxes. This report from Fidelity Investments explores the issue, providing assistance in calculating tax savings and explaining how a donor advised fund can reduce paperwork to make these donations easier.
By limiting the deductibility of investment-managing expenses by trusts, the Supreme Court's decision in the Knight case increases the taxes on trusts that use professional investment managers. This article by Richard LeVine of Withers Bergman examines the ruling and notes the need for innovative relationships between trusts and assets managers to ...
With short-term interest rates currently near zero, this may be a good time to consider using intra-family loans, grantor retained annuity trusts and sales to intentionally defective grantor trusts.