Gerald Nowotny – Law Office of Gerald R. Nowotny

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super…more
| Finance & Banking, Insurance, International Law & Trade, Securities Law, Taxation

Adeus, Brasil - Parte 1

Considerações estratégicas para profissionais e donos de empresas que desejam imigrar para os Estados Unidos. Descrição geral - Sou um advogado americano e concluí os cursos de espanhol e português na Academia Militar…more
| Immigration Law

Somewhere Over the Rainbow

The Use of Private Placement Group Variable Deferred Annuities in Generation Skipping Trusts - Over the last several decades, trust and estate lawyers have placed great emphasis on proper planning regarding the proper…more
| Insurance, Taxation, Wills, Trusts, & Estate Planning

A Buyer’s Market for MLPs in 2016

Using Private Placement Variable Deferred Annuity (PPVA) Contracts to Enhance the After-Tax Investment Return of Foreign Investors in MLPs - Overview - Master Limited Partnerships are publicly traded partnerships. As…more
| Business Organizations, Finance & Banking, International Law & Trade, Taxation

End of the Line – Part II: Year End Tax Planning Strategies

This article is Part II in a series of tax planning strategies for year-end tax planning for the 2015 tax series. The article addresses the Pooled Income Fund (PIF) which as this article demonstrates, has surprising planning…more
| Finance & Banking, Nonprofit Law, Taxation, Wills, Trusts, & Estate Planning

The End of the Line – Part I: Year End Tax Planning Strategies

This article is designed to provide an overview of a technique that might allow taxpayers to accomplish significant income tax savings at the end of the 2015 tax year. This planning can be accomplished regardless of whether you…more
| Finance & Banking, Nonprofit Law, Taxation, Wills, Trusts, & Estate Planning

This could be U! Explorando as possibilidades do Visto “U”

Panorama - Muitos imigrantes vêm para os Estados Unidos em busca de liberdade política e econômica, assim como segurança física. Infelizmente, muitos imigrantes podem ser vítimas de crimes quanto estão nos Estados Unidos…more
| Criminal Law, Immigration Law

Um recado na parede – a crescente maré de imigrantes: Posições dos candidatos à presidência sobre a reforma imigratória

Panorama - Nos últimos meses a imprensa americana tem feito a cobertura da Campanha Presidencial do Partido Republicano com a mesma intensidade que na Copa do Mundo. Uma das questões políticas que está no centro das…more
| Elections & Politics, Immigration Law

Tax-Savvy Planning for Foreign Business Owners Seeking Temporary U.S. Residence: Alternatives to the EB-5 Visa

The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the proposition…more
| Immigration Law, Taxation, Wills, Trusts, & Estate Planning

The Other EB Visa for Foreign Investors? EB-1(c) Visas as an Alternative to the EB-5 Visa

Overview - I have written a few articles regarding the over-promotion of the EB-5 visa program from the standpoint that frequently the foreign investor’s desire for a Green Card is over-zealous before considering all of the…more
| Immigration Law

Wimpy’s Investment Strategy for Foreign Real Estate Investors - Real Estate Deferral Options for Foreign Investors beyond the 1031 Exchange

Overview - I did not grow up watching much TV, or at least TV programming in English, growing up in the Panama Canal Zone. The Military’s AFRTS did not come on the air each day until around 4;30 in the afternoon. In the…more
| Real Estate - Commercial, Real Estate - Residential, Taxation, Wills, Trusts, & Estate Planning

Paradise Found! - The Use of PPLI Planning in Income Realization Planning in the Sale of a Capital Asset

I was at the PPLI conference in Boston a week and a half ago. Usually it is the same group of people saying the same things. However, this year was a little different. I have lived through several cycles of evolution of the PPLI…more
| Finance & Banking, Insurance, Taxation

Desde Panama Hasta Puerto Rico - Transitional Tax Planning Considerations Before You Move to Puerto Rico

Overview - My family lived in the Panama Canal Zone from 1960-2004. Even though it does not exist in its former status, I still consider it home. For most of the kids in my generation, it is their primary identification,…more
| Finance & Banking, International Law & Trade, Taxation

Férias de Verão! - Pensando nas posibilidades do Visto Estudantil

Resumo - Quando se trata de America Latina temos o ditado, “ Por mais que as coisas mudem, mais ficam iguais. Uma das consequências dessa instabilidade política e econômica e incerteza é que os latinos buscam qualquer jeito…more
| Immigration Law, International Law & Trade

Coming to America (for Business) - Using the L1 Visa as an Alternative to EB 5

Overview - As a long term veteran of the financial services industry, I have learned that in many cases, people do not “buy” a product or service but instead are “sold”” the product or service that the advisor is selling. A…more
| Immigration Law, Securities Law, Taxation
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