When does the state lack authority to tax a “resident trust” on out-of-state income? In this report, McGladrey discusses a number of strategies that advisers should consider in order to minimize the state-level tax liability for a trust by moving it to a more taxpayer-friendly jurisdiction. The article provides case studies dating back ...
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Using a New Hampshire trust, a settlor can eliminate a trustee’s reporting and disclosure requirements if he or she wishes to withhold knowledge of the trust’s existence, its terms, or the details of its holdings. Many settlors are turning to New Hampshire to create “quiet” or “silent” trusts under which the trus...
There are a number of trusts that can be customized to the needs of an investor, but each trust has its own advantages and disadvantages. This simple guide works to illustrate any concerns that an investor might have about tax consequences, withdrawal powers, the three-year rule and more by looking at the pros and cons of seven different popular ty...
Life insurance can play an important role in helping achieve the legacy and financial objectives of an individual or family—especially those with significant taxable estates and illiquid assets such as privately held businesses and real estate. For those who have assets that exceed the federal estate tax-exemption thresholds—$5,430,000 ...
In the past, when analyzing whether a client should make taxable gifts, estate planners tended to simply rely on comparing the transfer tax cost of making such gifts with those made at death. Paying the gift tax was assumed to be “cheaper” than paying estate tax, even though the rate was the same, because gift taxes are calculated on a ...
With the recent changes in the transfer tax laws, it is possible to transfer greater wealth and reduce income taxes through POAST. This innovative approach and integrated trust technique allow a wealthy individual (the donor) to provide benefits to both parents and descendants. A properly structured POAST can accomplish multiple objectives, includi...
The term “passion investments” has gained currency within the wealth management arena to describe high-end collectibles and other luxury possessions that hold emotional as well as financial value for their owners. When considering that this new asset class has generated noticeable returns, it’s no surprise that owners want to protect their high-val...
For each parcel of real property owned, the local assessor sends a Notice of Assessment, Taxable Valuation, and Property Classification. If it hasn’t already been received, it is on its way to the mailbox. Printed on the top of the Notice in big, red capital letters is: THIS IS NOT A BILL. So, most people are inclined to throw the Notice away...
In nearly every discussion about estate planning, important questions and issues arise. If couples arrive in their attorney’s office having already thought about these issues—including assessing the level of financial management skills their beneficiaries should possess, how to communicate to their children about their hopes and expectations about ...
As a result of the Wall Street Reform and Consumer Protection Act, the private family trust company (PFTC) has becomie a very popular vehicle to provide not only Family Office SEC exemption but also trust administration to the ultra wealthy inter-generationally and several additional tax and non-tax advantages. This memo identifies several of ...
When carried interest is transferred early in a fund’s life, it can have a very low value relative to its potential value at payout. It’s this payout potential that makes it an ideal asset to be used in estate tax-reduction planning, especially when used in combination with a grantor trust allowing for that appreciation to compound on a...
Portability may have been viewed initially as the simple solution in situations in which there was the potential for loss of the applicable credit amount of the first spouse to die. While this is a valuable benefit, the impact and potential planning opportunities for portability go beyond this important but somewhat limited scope.
Without a full understanding of U.S. federal gift tax and income tax issues associated with a gift of money to a U.S. child, it is easy for a nonresident alien to convert what would have been a tax-free gift to taxable income. This guide outlines the most common gift-giving mistakes and how to avoid them.
For foreign entrepreneurs seeking to bring their businesses to the United States, the EB-5 Immigrant Investor Visa may seem like the perfect fit. Looks, however, can be deceiving. Green card holders are subject immediately to U.S. federal income tax on their worldwide income and informational reporting requirements for their foreign interests.
New Hampshire has a robust set of modern trust laws, which afford settlors broad flexibility and creativity in designing trusts well suited to their specific needs and wishes. Those laws facilitate the more efficient administration of trusts and, importantly, provide a high level of certainty concerning the rights, duties and powers of settlors, be...