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Which Courts Have Jurisdiction to Deal with Claims Against Offshore Trustees?

There have been a number of cases decided recently by offshore Courts (particularly in Jersey and Bermuda), in which the Courts have had to consider the scope of their jurisdiction to determine disputes relating to trusts...more

Wealth Management Update - April 2014

April Interest Rates Hold Steady for GRATs, Sales to Defective Grantor Trusts, and Intra-Family Loans. The April applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Offshore Disclosure: What Needs To Be Disclosed? A Checklist

The following is a list of questions that should lead to the discovery of offshore assets, whether properly reported or not. If you answer yes to any of these questions, then you may have filing obligations and should seek...more

Q&A With Bilzin Sumberg's Richard Goldstein

Richard M. Goldstein is chairman of the tax and wealth preservation group in Bilzin Sumberg Baena Price & Axelrod's Miami office and represents numerous family businesses, U.S. residents and nonresident aliens, multinational...more

Americans Living Abroad Feel Impact of FATCA

According to some international financial experts, recently implemented American tax rates and policies may cause more Americans living abroad to renounce their U.S. citizenship. A recent conference in Israel on the subject...more

It’s A Small World After All

Our increasingly mobile society has forced estate planning to go international, too. You might have international estate issues: ? You have dual citizenship (US and another country) ? You are a non-U.S....more

International Practice Alert: September 2013 - When Can A Foreign Consulate Appear For A Foreign Citizen?

Estate litigation and probate proceedings are sometimes complicated when a beneficiary, close family member or other interested party is a citizen of a foreign nation. In an attempt to ease this burden, international...more

Financial Services Quarterly Report - Third Quarter 2013: Recent Developments in the Hong Kong Funds Industry

The Hong Kong Government has been keen to demonstrate its willingness to evolve and focus its efforts on the overall growth of the Hong Kong financial services industry. Recent proposals to make fund-friendly changes to Hong...more

Projected 2014 Inflation-Adjusted Figures

The IRS will issue inflation-adjusted transfer tax and foreign reporting items for 2014 based on fiscal year 2013 inflation, but it hasn’t done so yet. Thomason Reuters does its own computations of what it estimates will be...more

Foreign Investors In REITs: Opportunities Under FIRPTA Reform Proposals

Real estate investment trusts (REITs) have long been a tax-efficient vehicle for foreign persons seeking to invest in U.S. real estate. Now, two legislative proposals titled the Real Estate Investment and Jobs Act of 20131...more

Fiduciary Liability and Offshore Assets

Fiduciaries, like trustees and conservators, may face personal liability for wrongful acts in administering estates. Among the liabilities that a fiduciary may face is to the IRS for wrongful distributions such as those made...more

Sweeping Changes to the Pennsylvania Tax Code - The Passage of Pa. House Bill 465

House Bill 465, also known as Act 52, was signed into law by Pennsylvania Governor Tom Corbett on July 9, 2013. The Bill makes substantial changes to the Pennsylvania tax code as an integral part of the 2013–2014 budget....more

Energy Newsletter - September 2013

In This Issue: - New Rule Proposed By OSHA Regarding Silica Exposure Likely To Impact Fracking And Increase Risk Of Litigation - Texas Supreme Court Reaffirms Minerals Estate's Superior Rights -...more

"The Estate Planner" – September/October 2013

In this issue: - The GRAT: A limited time offer? - International relations: Estate planning for noncitizens - Avoid probate to keep your estate private - Estate Planning Red Flag – You Don’t Have...more

Lessons from Tony Soprano’s Estate Plan

James Gandolfini, a/k/a Tony Soprano, died unexpectedly at the age of 51. Not that we should all take money management lessons from a TV mobster, nor should we take guidance on estate planning from him, but the death of a...more

Estate of Turco: Is There Clawback For Insufficient Estate Tax Funds?

Estate of Turco: Is There Clawback For Insufficient Estate Tax Funds? by James F. McDonough, Jr. on August 15, 2013 The lack of liquidity is a serious problem in the administration of an Estate, especially for a...more

So, You inherited an unreported offshore account, now what!

There may have been a time when inheriting an unreported offshore financial account was not problematic; but not today. The executor/trustee of the estate of the decedent has fiduciary responsibility to IRS and faces personal...more

Six U.S. States Involved in Norwegian Tax Evasion Case

Six U.S. States Involved in Norwegian Tax Evasion Case by Frank L. Brunetti on August 12, 2013 In another example of international cooperation to quell Norwegian tax evasion, a quiet investigation is expected to reveal...more

Are U.S. Beneficiaries of a Foreign Estate Subject to Taxes?

When your father came to California many years ago, he left most of his family behind in Tokyo. However, you’ve gone back to Japan a number of times to visit and you developed a very close bond with your aunt. After receiving...more

CFTC Issues Final Guidance and Accompanying Exemptive Order on Cross-Border Application of Certain Swap Regulations

At a public meeting on July 12, 2013, the Commodity Futures Trading Commission (CFTC or Commission) adopted final guidance on how Dodd-Frank Act requirements will apply to cross-border swap activities (Guidance). In...more

Planning for Carried Interests & Avoiding Section 2701

Alternative investments in private equity and hedge funds have gained in popularity over the last two decades and have become a regular allocation of many investment portfolios....more

Friends and Relatives in Foreign Countries? They Can Still Be Part of Your Estate Plan.

The world continues to shrink as advances in technology fuel faster communication and travel to the far reaches of the globe. As a result, people are on the move now more than ever before. No longer is a move from San...more

Landmark US Supreme Court Decision May Extend US Tax Benefits to UK Civil Partners

On Wednesday, 26 June 2013, the US Supreme Court ruled that Section 3 of the Defense of Marriage Act (“DOMA”), which limits the definition of “marriage” to “a legal union between one man and one woman as husband and wife” and...more

Tax Technical Bill Receives Royal Assent

The most significant Canadian tax technical bill in over a decade (Bill C-48) is now law, receiving royal assent on June 26, 2013. The bill included over 900 pages of technical amendments that impact foreign affiliates,...more

I Want to "Leave" in America - Puerto Rican Residency as an Alternative to Expatriation

Overview - One of the things that generates political fireworks each year is the number and names of famous Americans renouncing their U.S. citizenship. The number is 2012 was about 1800. Regardless of whether you are...more

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