The new estate laws are challenging to comply with and will require most high net worth individuals to review their existing plan. One of the major issues is how the trust is divided on the death of the first spouse, and who...more
Final regulations were issued last month under IRC Section 336(e). These regulations present beneficial planning opportunities in certain circumstances....more
Although it may come as a surprise to many, it is no secret that South Florida property values are on the rise. ...more
In this article: - Income Tax - Other Foreign Taxes -- Vat And Social Security Taxes - Foreign Tax Credit Planning - U.S. Withholding Obligations - Use Of Loan Out Company -...more
One of the funding mechanisms for health care reform is a new 3.8% Medicare contribution tax on net investment income (NII) going into effect this year. The tax applies to higher-income individuals as well as to trusts and...more
In This Issue: - Taxpayer Relief Act of 2012 - Tax Planning for the “New Normal” - HIPAA: Not Just for Health Care - ADA Requirements for Pools - Impact of Dodd-Frank Swap Regulations on Loan Documents -...more
In Virginia P.D. 13-84 (Feb. 28, 2013), the Department of Taxation clarified how a manufacturer who seeks single sales factor treatment can calculate the “average number of full-time employees for the base year” and “in each...more
The American Taxpayer Relief Act of 2012 (the “2012 Act”) had a profound impact on the transfer tax system. I will briefly describe that system and then, by way of background, set the stage for these changes by summarizing...more
Effective January 1, 2013, the American Taxpayer Relief Act of 2012 (“ATRA”) was enacted into law, finally settling years of debate over the fate of the Bush era tax cuts. On the same day, the 3.8% Medicare Tax on net...more
In a decision issued last week, the U.S. Court of Appeals for the Third Circuit held that a debtor’s qualified subchapter S subsidiary (QSub) status is not property of the bankruptcy estate. The Third Circuit’s opinion...more
The recent Congressional hearings on taxation of multinational corporations drew a lot of focus on the low tax rates and low taxes paid (relative to revenue). Congress expressed outrage that the largest companies in the world...more
In Brianne Gwartz v. The Queen, 2013 TCC 86, the Crown attempted to utilize the GAAR to recharacterize as dividends certain capital gains which had been realized by a family trust and allocated to the minor-aged taxpayers in...more
Following the announcement in Budget 2013, HM Revenue & Customs (HMRC) issued a consultation document on May 20, 2013 that focuses on two areas of partnership taxation where HMRC perceive “unintended inconsistencies”...more
One of the provisions included in the health care reform legislation enacted in 2010 will subject certain individuals to a 3.8% tax on net investment income (or "unearned income"). The new law is effective in 2013 and imposes...more
In this presentation: - Introduction - Trademark/Brand Strategy and Protection - U.S. Foreign Corrupt Practices Act and Anti-Corruption - Cross-Border Tax Planning and Compliance Please see...more
Overview - This article discusses the use of private placement products - private placement deferred variable annuities (PPVA) and private placement life insurance (PPLI)- in post mortem income tax and transfer tax...more
On April 10, 2013, the White House released its proposed budget for fiscal year 2014. The budget contains significant tax proposals related to renewable energy, research and job creation, as well as numerous changes affecting...more
Overview - In case you did not know, Miami is the capital of Latin American. It is the port of entry for Latin Americans from Central and South America. Historically, wealthy Mexicans have liked California and Texas...more
In This Issue: - Exemption portability: Should you rely on it? - Decant a trust to add trustee flexibility - Using the GST tax exemption to build a dynasty - Estate Planning Red Flag: Your plan includes a...more
Overview - As discussions regarding immigration reform continue to unfold, one point that is not under discussion or subject to debate is the contribution of foreign scientists and engineers to the New Economy. The statistics...more
When private equity or venture capital fund principals and managing partners look to roll out a new fund, in addition to reconciling general fund formation issues, they should consider the personal-planning opportunities...more
Overview - My last article focused on the attractiveness of Puerto Rico for hedge fund managers . Poor John Paulsen cannot make a move without the financial press reporting on the story. If he bought a Big Gulp at...more
A debtor, regardless of state residence, can seek protection from his or her creditors in the federal bankruptcy courts. However, the state in which the debtor resides or, more accurately, is "domiciled," will determine which...more
Budget 2013 was tabled on March 21, 2013. Heenan Blaikie’s National Tax Group has prepared the following overview of some of the more significant tax-related measures....more
The "paradise" stories for the post-playing careers of professional athletes are without a doubt under told. The success of Roger Staubach in building a real estate empire, the multiple businesses of NBA all-stars Magic...more
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