Investors are well advised to take into account the interest rate environment when considering wealth transfer options. A new white paper from Fiduciary Trust points out the importance of interest rates in creating trusts, reviewing estate plans and loaning money to family members. The paper then examines three wealth transfer options that work wel...
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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....
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.