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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.

This quarterly newsletter features the articles, "Estate Planning Key to Succession Planning," Exploring the Ins and Outs of Net Operating Losses," and "Tax Tips."

With only a few months to go until the end of the year, those who have not fully used their available lifetime gift, estate and generation skipping transfer exemptions may be running out of time. This paper outlines some ideas for making relatively simple and quick use of the opportunity, so that it does not go to waste.

The windfall of inherited wealth often comes with feelings of guilt and elation, isolation and confusion. No wonder; when the financial gain is due to the loss of a loved one’s life, it feels crass to be excited about the opportunities an inheritance affords. Learning to be comfortable with inherited wealth is a process, a process of moving through...

The sale of a business can be one of the most significant events for families of wealth. Often, family members have devoted substantial time and resources to building a successful enterprise.While the sale of the business may be viewed as the successful culmination of years of work, it may also cause concern for the owner, who feels there is not en...

On 18 March, the Russian Ministry of Finance published a draft law on anti-offshore measures (the Draft). This article by Withers LLP provides a thoughtful review of the Draft, which introduces three concepts:Controlled foreign companies rules (CFC)Russian tax residence for foreign companies based on tests of management and controlNew rules on taxa...

For families contemplating substantial charitable contributions, private foundations provide a structure to create a legacy of family charitable giving and remain a popular vehicle for charitably inclined families.While a private foundation may appeal to an individual for a variety of reasons; private foundations come with responsibilities. Prior t...