News & Analysis as of

Asset Management Income Taxes

Shumaker, Loop & Kendrick, LLP

The Estate Planner, July/August 2024

Employee stock ownership plan - A versatile business exit and estate planning tool - If you own a closely held business, a significant portion of your wealth may be tied up in it. So, to prepare for retirement and...more

Proskauer Rose LLP

UK Tax Round Up - March 2024

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Welcome to March’s edition of our UK Tax Round Up. This month has seen a number of interesting cases covering a range of issues, from the deductibility of costs against employment income to the place of effective management...more

Husch Blackwell LLP

Understanding the Unique Benefits of Beneficiary Intentionally Defective Irrevocable Trusts (BIDITs)

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A Beneficiary Intentionally Defective Irrevocable Trust (BIDIT) provides a unique planning opportunity because it allows a beneficiary to continue to benefit from his or her own assets while maintaining some level of control...more

Proskauer - Tax Talks

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

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On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more

Greenberg Glusker LLP

Top Tax and Legal Considerations for Wealthy Families Going Global

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In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Katten Muchin Rosenman LLP

Greener Pastures: Five Things to Consider When Leaving One Jurisdiction for Another

Is the grass always greener on the other side? Like any major life decision, deciding to uproot yourself (and potentially your family) and move from one state to another is not an easy decision. Although laws, taxes and...more

Akin Gump Strauss Hauer & Feld LLP

UK Mini-Budget - Helpful for Asset Managers

The government’s 2022 Growth Plan, deceptively referred to as the “mini-budget,” has brought in notable changes likely to impact the funds industry. In particular, a number of the changes will help ensure the continued...more

Proskauer - Tax Talks

BlueCrest FTT Decision –  Salaried Member Rules and Asset Managers

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The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first time the UK’s salaried member rules (the Rules) have been considered in the context of an asset...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Freeman Law

What is a Trust?

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Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more

Freeman Law

Releases and Family Settlement Agreements in Trust & Estate Litigation

Freeman Law on

A settlement agreement can be beneficial to all parties – it may help reduce litigation costs, facilitate dispute resolution, or guide the parties to a common understanding. However, settlement agreements do not come without...more

Gerald Nowotny - Law Office of Gerald R....

NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!

Cutting edge ideas and tools to raise assets under management (AUM) and succeed as a financial advisor. #pooledincomefund #financialadvisor #taxes...more

Gerald Nowotny - Law Office of Gerald R....

NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!

Nowotny On Death and Taxes episode #33 (Nowotny Knows Squat!) discusses how a customized pooled income fund (PIF) can be used as a creative method to assist a client in minimizing capital gains taxation on the sale of an...more

Farella Braun + Martel LLP

Estate Tax Planning for Large Company Stock Holdings: Four Tips for Using Record-High Lifetime Exemptions

- Annual inflation-indexing continues to increase the historically high lifetime exemption amount for gift, estate, and generation-skipping transfer taxes. Those of considerable wealth who have not yet made gifts, such as...more

BakerHostetler

State Tax in Transactions - Expanding Nexus Footprint (Part II)

BakerHostetler on

M&A transactions can have big implications for your company's nexus footprint. In part two of the series on M&A transactions, Matt Hunsaker breaks down nexus issues that should be on your radar if your company is engaging in...more

Steptoe & Johnson PLLC

Selling Assets to Reduce Your Estate Tax Exposure - Act Before September 30

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If you have an estate that may be subject to estate tax next year, particularly if the November election results in a greatly reduced federal estate tax exemption in 2021, now is the time to remove assets from your taxable...more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR

Best way to structure your business to own multiple businesses in real estate and investment activities. Key benefits: Management and Control, Asset Protection, No FICA and Medicare Withholding and Ability to stagger a tax...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner - July/August 2020

Don’t overlook foreign assets when planning your estate - You’d be surprised how often people fail to disclose foreign assets to their estate planning advisors. They assume that these assets aren’t relevant to their “U.S.”...more

Shumaker, Loop & Kendrick, LLP

The Estate Planner - January/February 2020

Now or later - When’s the right time to transfer your wealth? - To gift or not to gift? It’s a deceptively complex question. The temporary doubling of the gift and estate tax exemption — to an inflation-adjusted...more

McDermott Will & Emery

[Event] 2019 Tax In The City®: Seattle - October 24th, Seattle, WA

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We invite you to join us for a discussion on current tax issues including: • Judicial deference and potential impact on TCJA audits • Developments and planning considerations for intangible assets o US tax...more

Holland & Knight LLP

A New Tax for an Economy in Crisis

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The National Constituent Assembly (ANC) on July 2, 2019, issued the constitutional law that created the Wealth Tax (Impuestos a los Grandes Patrimonios). The creation of this tax reopens the debate on the constitutionality of...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

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On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Dechert LLP

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

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Publication of decrees amending the regime of French direct lending funds - The Ordinance n° 2017-1432 of 4 October 2017 introduced the possibility for "financing vehicles" (organismes de financement, OF) to grant loans....more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding Tax and Reporting Action Items for Investment Funds and Asset Managers (Fall 2018)

• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more

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