Offshore Considerations For Non-UK Domiciliaries
On April 6, comprehensive tax changes went into effect in the United Kingdom (U.K.) that impact wealth planning considerations for certain individuals who spend a significant amount of time in the U.K., but who are domiciled outside of the country. Source:...President Trump Signs Financial Services Executive Orders – YouTube
QDOT-ting I’s and Crossing T’s: Estate Tax Planning for Non-United States Citizen Spouses
Good examples in this article on QDOT planning: The examples above illustrate the general rules applicable to gratuitous lifetime transfers of property, or gifts. The following examples illustrate the general rules applicable to transfers at death: Source:...What Is Community Property, and What Are Community Property Trusts?
Community property is treated preferentially by the tax code — it gets a full step-up in basis at death, instead of only stepping up the decedent’s half as in joint tenancy. (Could also step down if the market timing is unlucky, but that is rare.)...Tax Havens Can Be Surprisingly Close to Home
Nations lose hundreds of billions of dollars every year through tax evasion and avoidance facilitated by havens. Gabriel Zucman, an economist at the University of California, Berkeley, has estimated that as of 2013, about 10 percent of the world’s...New Commodity ETFs Structured to Avoid Need for K-1 Filing
ETF Securities Group, a U.K.-based asset manager, launched three ETFs on the NYSE Arca exchange that track the Bloomberg Commodity Indices, on March 31. The funds are among thousands traded on the exchange but stand out because they are broad-based and...The flexibility of stretch IRAs: Learn how your IRA can benefit your spouse and other beneficiaries
IRA stretch is great in theory, but your beneficiary can withdraw the principal at any time and there is no asset protection. As an estate planning attorney, I can make the stretch real by using an asset-protected standalone IRA Beneficiary Trust, separate from...States With the Highest (and Lowest) Taxes for Retirees
In general, the most tax-friendly states for retirees are, in order, Alaska, Delaware, Georgia, Nevada, and Wyoming, according to the J.P. Morgan report. The least tax-friendly states, in order, are New Jersey, Connecticut, New York, Maine, and Vermont. Property taxes...Should you use your retirement savings to pay for kids’ college? – MarketWatch
The kids can work their way through college like we did. ‘Should I dip into my retirement account to pay for college?’People do it, but most financial professionals advise against it. At the very least, experts say, you should limit such withdrawals, so as not...IRS Recognizes Retroactive Validity of GRAT Based Upon Court Reformation
In this matter, the draftsman failed to include language prohibiting the trustee from issuing a note, other debt instrument, option or other similar financial arrangement in satisfaction of the annuity obligation as required by § 25.2702-3(d)(6) of the Gift Tax...Estate Planning Pitfall: You reside in a state with high estate tax
Sacramento is at this moment plotting to bring back the estate tax here. Also, you might own property, or plan to retire, in one of these states. Do you have a flexible estate plan? Reforms being debated by Congress could repeal the federal estate tax with...Conflicted Art Appraisals Lead to $1.77 Million Estate Tax Deficiency
Recently, in Estate of Kollsman v. Commissioner (T.C. Memo. 2017-40), the U.S. Tax Court held that an art collector’s estate significantly underreported the value of two artworks for estate tax purposes. The problem: the estate relied on appraisals by an...Make GRAT Payments to Avoid Subjecting Assets to Gift Tax
A GRAT must be drafted to comply with the requirements set forth in the applicable Treasury Regulations under Section 2702. Unfortunately, the regulations don’t resolve all issues, such as whether there’s a minimum or maximum term for a GRAT, or whether a GRAT...Do You Still Need An Estate Plan If There Is No Estate Tax?
In other words, a repeal of the estate tax would really only impact those clients with a net worth north of $11 million. That’s why Natanya told me that most of her moderately wealthy clients have already rounded the corner from thinking about taxes to focusing...Dynastic Gamesmanship: Did David Rockefeller’s Crafty Trust Work Leave the IRS Holding the Bag?
The trust rules have evolved over the last eight decades. For one thing, depending on the state, a trust created now for David’s own grandchildren and beyond may never need to terminate.It could theoretically run forever, eternally beyond IRS reach if run...Term Life Insurance and Pre Liquidity Planning
From a planning perspective, illiquid shares provide a challenging dilemma. Restricted shares can generate a high balance sheet net worth and high estate value, but oftentimes without the corresponding liquidity to fund the shareholder’s estate tax liability....FATCA Repeal On Agenda Of U.S. Republicans
“FATCA has wrecked [sic] havoc on the global financial system, turned 8 million Americans overseas into financial pariahs, violates other countries’ sovereignty, and is damaging for American jobs and therefore the American and global economies,” he said....Tax Reform Bill On the Front Burner
In short, the ground has been laid for quick action in the House of Representatives the moment the health care debate concludes. Source: Tax Reform Bill On the Front BurnerCharitable Divorce Planning?
Charitable planning coordinated with dissolution planning merits serious examination. The work involved is well worth the effort to assure divorcing parties have maximized the use of all marital assets in a tax-efficient manner. The four techniques are...
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