Tax Law, International Law & Trade, Wills, Trusts, & Estate Planning

FBAR Penalties and Estate Administration

by Sanford Millar on 5/20/2013

The death or disability of a taxpayer who has failed to timely file a Report of Foreign Bank or Financial Account (FBAR) can present difficult problems for fiduciaries like trustees, estate executors and conservators. The...more

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

by David Gair | Looper Reed & McGraw, P.C. on 5/13/2013

The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more

Foreign Account Tax Compliance Act (FATCA) Registration

by Darren Mills | Berkeley Research Group, LLC on 5/6/2013

Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a...more

International Business, Tax, Estate and Asset Preservation Planning - April 2013: Expatriation Tax Rules: Green Card Holders...

by Stephen A. Malley, APC on 4/26/2013

The curiously titled "Heroes Earnings Assistance and Relief Tax Act of 2008" became law 17 June 2008. This was the third major revision of expatriation rules in 12 years. While the Act provides laudable benefits to armed...more

Considerations For International Clients Who Intend to Buy A Home In the U.S.

by Amy McEvoy | Sheppard Mullin Richter & Hampton LLP on 4/23/2013

International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with...more

German Federal Tax Court: Distributions from U.S. Trusts Are Subject to German Gift Tax

by Florian Reichthalhammer, J. Andrew Stone | McDermott Will & Emery on 4/10/2013

The German Federal Tax Court clarified that distributions from foreign trusts to beneficiaries resident in Germany are subject to German gift taxation, but did not address the possible imposition of both gift and income tax...more

Personal Use Of Corporate Property In A USRPI Holding Company Structure

by Charles (Chuck) Rubin on 4/1/2013

To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more

March 2013 Federal Budget Provisions Concerning Pipeline Abandonment Trusts

by Marie Buchinski, Robert McCue, Lawrence Smith | Bennett Jones LLP on 3/26/2013

Overview - The March 21, 2013 Federal Budget changed the tax law applicable to the pipeline abandonment trust (Trust) structure that has been submitted to the National Energy Board (NEB) as the proposed mechanism for...more

Private Client - Practical Law Multi-Jurisdictional Guide 2012/13 Country Q&A: Japan

by Shinichiro Kurahara, Takeo Mizutani, Michael Shikuma, Tadashi Wada | Morrison & Foerster LLP on 3/14/2013

Originally published in Private Client Multi-Jurisdictional Guide 2012/13. In This Issue: Taxation; Wills and Estate Administration; Succession Regimes; Intestacy; Trusts; Ownership and Familial Relationships;...more

Disclaimer Of Income Interest Was Not Taxable For Nonresident

by Charles (Chuck) Rubin on 2/8/2013

Code §2501(a)(2) provides that, except as to certain expatriates, U.S. gift taxes do not apply to the transfer of intangible property by a nonresident not a citizen of the United States. This exemption is big enough to drive...more

FATCA: Final Regulations Raise Questions for Trust Practitioners

by Sloane Jumper, Samantha Moore, John Nichols, Kurt Rademacher | Butler, Snow, O'Mara, Stevens and Cannada,... on 2/8/2013

In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more

Tax Talk -- Volume 5, No. 4 -- January 2013

by David de Ruig, Stephen Feldman, David Goett, Thomas Humphreys, Meimay Law, Anna T. Pinedo, Remmelt Reigersman | Morrison & Foerster LLP on 1/28/2013

In This Issue: Fiscal Cliff Diving a.k.a. American Taxpayer Relief Act; CoCo Developments; Tax Effect of Money Market Fund Proposals; IRS Issues Final Regulations on Publicly Traded Property; Assessment of Income from...more

UK property tax changes: “de-enveloping” or a use of a trust?

by Henry Mander, Colin Riegels | Harney Westwood & Riegels on 1/21/2013

It has long been popular for high net-worth people who are not domiciled in the United Kingdom (“non-doms”) to form an offshore company, often in the British Virgin Islands (“BVI”), for the purposes of holding property in the...more

U.S. Estate Planning For Expatriates

by Charles (Chuck) Rubin on 12/28/2012

Code §2801 imposes U.S. transfer taxes on transfers by former U.S. persons who have expatriated if the transfer is to a U.S. person. This tax is imposed on the U.S. recipient. A recent article by Joseph Toce, Jr. and Joseph...more

2012 Year-End Estate Planning Advisory

by Katten Muchin Rosenman LLP on 11/21/2012

Now that the election is over, we anticipate having some guidance soon with respect to the numerous tax and planning issues that have been mired in uncertainty for the past two years. Many tax benefits are scheduled to...more

Rappelling Down the Fiscal Cliff – Strategies for Cushioning the Fall – Part II

by Gerald Nowotny on 11/14/2012

A. Overview - Part I of this series focused on the impact of impending tax increases following the Presidential Election for corporate executives and salaried professionals. Part II of the series will focus on...more

Commentary on October 24, 2012: Technical Bill

by Osler, Hoskin & Harcourt LLP on 11/8/2012

On Wednesday, October 24, 2012 the Canadian Federal Department of Finance tabled in the House of Commons a large detailed Notice of Ways and Means Motion (“NWMM”) to amend the Income Tax Act (Canada) and a variety of other...more

Canadian Government Moves to Implement Amended Non-Resident Trust and Offshore Investment Fund Property Rules

by Osler, Hoskin & Harcourt LLP on 11/6/2012

On October 24, 2012, the Federal Minister of Finance released a detailed Notice of Ways and Means Motion to implement outstanding technical tax amendments, including significant amendments to Canada’s income tax rules...more

Should you Opt-Out of the Voluntary Disclosure Program? [Video]

by Sanford Millar on 10/22/2012

When is it right to op-out of the voluntary disclosure program, knowing when to stay in and when to get out could be the difference of saving a massive amount of money and staying out of jail. Talk to a professional who can...more

Staying clear of the IRS - Tips for estate planning and tax law compliance in a global economy

by Greenberg Glusker Fields Claman & Machtinger... on 9/28/2012

Originally published in Insights Legal Affairs. Do you own a vacation home in Mexico? Have a bank account in Hong Kong? Has your spouse retained Canadian citizenship? Are you a long-term U.S. resident who was born in the...more

French Trust Law Reporting Requirements

by Leigh-Alexandra Basha | Holland & Knight LLP on 9/27/2012

Last year France passed legislation which is aimed at taxing assets held through trusts where there is a connection with France. Effective as of July 31, 2011, this legislation imposes tax reporting obligations on trustees...more

Blame The Professional’ Defense Does Work Sometimes

by Charles (Chuck) Rubin on 9/4/2012

Dr. James formed an irrevocable trust in Nevis, West Indies for asset protection purposes. He properly reported the trust to the IRS on a Form 3520-A, but neglected to file a Form 3520. He is at risk for a penalty of the...more

Practical Tips for U.S. Persons Owning Mexican Property Thru a Fideicomiso

by Snell & Wilmer L.L.P. on 8/15/2012

Every time I’m presented with a contract, I’m quickly transported to a small room in which Willy Wonka, played by Gene Wilder, is vehemently scolding the good natured Charlie Bucket and the poor, protective Grandpa Joe: ...more

U.S. Taxation of Fideicomisos under the FATCA Rules

by Moskowitz LLP on 8/8/2012

Overview of Fideicomisos If you own a home or a vacation home in Mexico, chances are that your property is held in a fideicomiso. A fideicomiso is a contractual arrangement that is arguably something in between a trust...more

Death and Foreign Asset Disclosure. What you don't know can cost you…a lot [Video]

by Sanford Millar on 7/29/2012

When someone dies with foreign assets, the heirs need to know the law and what their options are to best preserve the bulk of the inheritance. It can be a complicated business sorting out foreign assets and well worth your...more

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Tax Law › International Law & Trade › Wills, Trusts, & Estate Planning

FBAR Penalties and Estate Administration

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

Foreign Account Tax Compliance Act (FATCA) Registration

International Business, Tax, Estate and Asset Preservation Planning - April 2013: Expatriation Tax Rules: Green Card Holders...

Considerations For International Clients Who Intend to Buy A Home In the U.S.

German Federal Tax Court: Distributions from U.S. Trusts Are Subject to German Gift Tax

Personal Use Of Corporate Property In A USRPI Holding Company Structure

March 2013 Federal Budget Provisions Concerning Pipeline Abandonment Trusts

Private Client - Practical Law Multi-Jurisdictional Guide 2012/13 Country Q&A: Japan

Disclaimer Of Income Interest Was Not Taxable For Nonresident

FATCA: Final Regulations Raise Questions for Trust Practitioners

Tax Talk -- Volume 5, No. 4 -- January 2013

UK property tax changes: “de-enveloping” or a use of a trust?

U.S. Estate Planning For Expatriates

2012 Year-End Estate Planning Advisory

Rappelling Down the Fiscal Cliff – Strategies for Cushioning the Fall – Part II

Commentary on October 24, 2012: Technical Bill

Canadian Government Moves to Implement Amended Non-Resident Trust and Offshore Investment Fund Property Rules

Should you Opt-Out of the Voluntary Disclosure Program? [Video]

Staying clear of the IRS - Tips for estate planning and tax law compliance in a global economy

French Trust Law Reporting Requirements

Blame The Professional’ Defense Does Work Sometimes

Practical Tips for U.S. Persons Owning Mexican Property Thru a Fideicomiso

U.S. Taxation of Fideicomisos under the FATCA Rules

Death and Foreign Asset Disclosure. What you don't know can cost you…a lot [Video]

Should you Opt-Out of the Voluntary Disclosure Program? [Video]

Death and Foreign Asset Disclosure. What you don't know can cost you…a lot [Video]

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