Gerald Nowotny – Osborne & Osborne, PA

798 S. Federal Hwy, Suite 100
Boca Raton, FL 33432, United States

  • 561-395-1000 Ext:.108
  • 860-490-9689

Bye Bye Brazil – Considerações Tributárias no Planejamento de Investimento Brasileiro dentro dos Estados Unidos - Parte 1

Sou advogado tributário americano. Me formei na academia militar do exército americano em West Point, Nova Iorque. Me graduei em Espanhol e Português. Meus professores eram um tentente coronel do exercito brasileiro formado na…more
| Finance & Banking, Immigration Law, Taxation

Jamon y Queso (Ham and Cheese) – Offshore Annuity Planning Options for Non-Resident Aliens

I have been active in private placement life insurance since 1999. Over that course of time, while the offshore private placement life insurance industry was getting its start in the late 1990s, Sun Life of Canada introduced an…more
| Finance & Banking, Insurance, International Law & Trade, Taxation

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part 3 - Inbound Investment Real Estate in the U.S Commercial Real Estate

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team…more
| Finance & Banking, Immigration Law, International Law & Trade, Real Estate - Residential, Taxation

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part II – Additional Income Tax Considerations

I have mentioned in prior articles my affiliation with the South Florida law firm Osborne and Osborne, PA in Boca Raton. Back to the beginning! Boca Raton is where I started right out of the Army in 1987. I moved to Miami for…more
| Finance & Banking, Immigration Law, International Law & Trade, Real Estate - Residential, Taxation

Bye Bye Brazil!- Tax Planning Considerations for Brazilian Investment in the United States: Part I – Income Tax Considerations

Overview - I have mentioned in prior articles that I was a Spanish and Portuguese major as an undergraduate. During the time that I was attending law school at the University of Miami, the early 1990’s, the Brazilians had…more
| Finance & Banking, Immigration Law, Taxation

The Waters of March -The Benefits of Owning Life Insurance within a Cascading Charitable Lead Annuity Trusts (CLATs)

...I recall hearing Bossa Nova as a ten year old at my neighbor’s house in the Panama Canal Zone – Sergio Mendes and Brazil 66. The Waters of March is one of many great songs written by Antonio Carlos Jobim and sung by Elis…more
| Commercial Law & Contracts, Finance & Banking, Insurance, Taxation, Wills, Trusts, & Estate Planning

Can We Talk? Providing Hedge Fund Managers with the Deferral of Carried Interest until Eternity

Overview - The recent passing of Joan Rivers not only requires us to pay tribute to one of the great comedic minds of the last forty-fifty years, but serves as a testimony to professional passion, perseverance and hard…more
| Commercial Law & Contracts, Finance & Banking, Insurance, Taxation

If I Had a Hammer – A Creative Method for Repatriating Offshore Corporate Profits

In this era of corporate inversions, there seems to be a lot of mud-slinging going around. Congress and the current Presidential administration would like to label large multi-national corporations as traitors. Somewhere along…more
| Commercial Law & Contracts, Labor & Employment Law, Finance & Banking, Insurance, Taxation

Give unto Caesar (but not a Dollar More!)-The Benefits and Planning Dexterity of the Charitable Lead Annuity Trust

Overview - I have to admit that I was a pretty good high school Latin student. In fact it may have been my best subject. When I got to West Point, I was in for very rude awakening. Not only did I realize too late that the…more
| Commercial Law & Contracts, Finance & Banking, Insurance, Taxation, Wills, Trusts, & Estate Planning

From Here to Eternity or San Juan! - Transitional Tax Planning with Pre-IPO or Appreciating Closely Held Stock

Speaking of Eternity, I must admit that I am a big fan of gospel music. While I like old school or traditional gospel, I prefer the newer R&B urban sound popularized beginning with Andrew Crouch and later Fred Hammond and…more
| Business Organizations, Commercial Law & Contracts, Finance & Banking, Taxation

Tax “Brujeria” - Transitional Tax Planning Considerations to Move Your Business to Puerto Rico

The other day I asked the garage attendant who was of Puerto Rican (PR) ancestry and listening to Salsa music as she worked, which group was the most influential band in her estimation – La Sonora Poncena or El Gran Combo. For…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself; (2)…more
| Commercial Law & Contracts, Finance & Banking, Taxation, Wills, Trusts, & Estate Planning

Swimming in the Deep End – The Surprising Utility of Pooled Income Funds for High Net Worth Tax Planning

Overview - The old cliché about Charity is that “Charity begins at home.” The federal government has always recognized the social benefit of providing tax incentives for individual and corporate taxpayers in order to…more
| Commercial Law & Contracts, Finance & Banking, Taxation, Wills, Trusts, & Estate Planning

San Juan – The New Havana?: Making the Move from Miami to Puerto Rico

I lived in Miami for about ten years during the time that I went to law school at the University Of Miami School of Law, i.e. the Harvard of the South! I also worked in Miami while I went to law school at night and have a good…more
| Commercial Law & Contracts, Finance & Banking, Taxation

Discriminatory Defined Benefit Plans: Finding Retirement Gold in the Least Likely of Places

We live in politically charged times. Congress seems unable to reach a consensus on anything, including where to have the annual congressional Christmas ball! Years of political crossfire over the Affordable Care Act have drawn…more
| Labor & Employment Law, Finance & Banking, Taxation
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Areas of Practice
  • Finance & Banking
  • Insurance
  • International Law & Trade
  • Taxation
  • Wills, Trusts, & Estate Planning
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