The New Cold War: Risk, Sanctions, Compliance Episode 20: "Rich Russians: From Oligarchs to Bourgeoisie"
Papa Has a Brand New Bag
All in the Family – Introducing Family Owned Life Insurance™ (aka FOLI™)
Family Affair - Introducing Family Office Life Annuity (FOLA)
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
HIPPER THAN HIP
Financial Planning For Health Care Professionals
IT NEVER RAINS IN SOUTHERN CALIFORNIA - INTRODUCING THE MALTA FREEZE
Making Cents of Your Cash Management Agreements
Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more
El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more
On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more
On February 21, 2024, the IRS announced plans to begin audits on aircraft that may be used for both business and personal purposes. This push is a part of the IRS’s broader focus on improving tax compliance in high-income...more
The City of Los Angeles ULA Tax—a new city tax on certain real estate transactions, commonly referred to as the “mansion tax”—may be invalidated through the November 2024 election....more
The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted. The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more
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
On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will establish a special...more
The IRS has recently issued an ominous notice (#IR-2023-126) in which the IRS warns high income US taxpayers and millionaire non-filers that the IRS is targeting them to conduct audits, identify and collect undeclared income...more
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
As President Biden reminded taxpayers in his recent State of the Union address, the federal government continues to pursue new taxes on high-net-worth individuals. While such efforts have foundered in Congress, causing many...more
The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more
Residents of Los Angeles have approved Measure ULA, a ballot measure widely known as the “Mansion Tax,” which increases transfer tax rates on real estate sales valued at $5 million or more. Prior to Measure ULA, real estate...more
Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more
On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
The US Treasury reports that it is expecting the tax gap to rise to approximately $7 trillion over the course of the next decade if left unaddressed. In May 2021, the US Department of the Treasury issued the “THE AMERICAN...more
En el comentario “A Closer Look: Impacting the Tax Gap”, el Comisionado del IRS, Chuck Rettig, revela que el IRS ha cambiado su enfoque de fiscalización a declaraciones de impuestos que incluyen contribuyentes de altos...more
In its April 28, 2021 Press Release (the “Release”) “Investing in the IRS and Improving Tax Compliance”, the US Department of the Treasury addresses available enforcement activities relating to reducing the U.S. Tax Gap;...more
The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net Worth Individuals...more
The difference between the amount of tax owed by Taxpayers for a given year and the amount that is actually paid timely for that same year is known as the “Gross Tax Gap”. The IRS looks at this number as an estimate of the...more
Divorce is not a topic most clients or tax advisors enjoy discussing. Nevertheless, it is important in today's day and age to advise clients, especially high-net-worth individuals with substantial assets located in the U.S....more
Democrats at both the federal and state levels are proposing a “mark-to-market” tax and legislation that would mandate more audits on high-income taxpayers....more
El 3 de diciembre del 2020, el IRS publicó “Cómo el IRS prioriza el trabajo de cumplimiento en los no declarantes de altos ingresos a través de esfuerzos nacionales e internacionales” en el Estudio titulado “Closer Look”. El...more
On December 3, 2020, the IRS published “How the IRS prioritizes compliance work on high income non-filers through national and international efforts” in the Closer Look. ...more