The IRS revenue ruling regarding the deductibility of management fees by limited partners of partnerships that invest in other partnerships tends to target funds of funds. WTAS believes this ruling may have a wider effect on any tiered partnership structure.
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.
When it comes to reaching your family’s financial objectives and perpetuating its wealth, integrated family wealth planning is critical. A family governance system can significantly facilitate that process. This evergreen guide offers best practices and key elements of an effective family governance system, one that can be instrumental and flexible...
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.
Low interest rates are certainly disheartening for investors looking for income, but they also drive down key rates used in estate planning – a great benefit to those looking for low or no tax techniques for transferring wealth to family members. It is unlikely, however, that these rates will remain as low as they currently are.
The charitable lead trust can be used effectively for the ultra-wealthy to pass property, at death or during life, to charity and family members. The trust is particularly effective for individuals who want to address their charitable interests and also set aside money for future generations' medical, educational or other needs.
Designed to exist perpetually, promote family values and provide a substantial legacy, a dynasty trust takes the greatest possible advantage of a donor's gift tax and generation-skipping transfer tax exemptions. The trust property and the appreciation on that property remain in trust out of the family's successive estates. However, the flexibility ...
These harsh economic times should induce beneficiaries, fiduciaries and their advisors to review trust distributions and portfolio viability. Whether investment and inflation conditions get worse or improve, if everyone takes a long hard look at the economic reality and works together, they can devise a deliberate and practical trust plan that will...
Savvy investors have always known that an economic downturn presents opportunities for anyone willing to bet on a recovery. Similarly with estate planning, there are distinct advantages in taking action while market values and interest rates are low. By transferring property now, individuals can reduce the size of their taxable estates while giving...