Until recently, there was a fair amount of comfort amongst practitioners that, when structured correctly, utilizing a tax reimbursement clause for a grantor trust did not produce any negative U.S. gift or estate tax results....more
The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following:
US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more
11/14/2023
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Estate Tax ,
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Tax Planning
What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more
The IRS recently released its annual Revenue Procedure containing inflation-adjustments for 2021. Of interest to international tax and estate planning practitioners are the following...more
On August 28, the IRS announced that it would temporarily accept e-signatures on certain forms. Included among that initial list of forms was Form 8832, Entity Classification Election (commonly known as a “check-the-box”...more