Authored by: Neeli G. Shah On March 26, 2012, the United States Tax Court issued a memorandum opinion in Wandry v. Commissioner, which was an important taxpayer victory in the world of defined value clauses (“DVC”). A DVC is a formula clause that allows the taxpayers to determine a gift’s fair market value, for federal [...]
Tags: NShah
Authored by: Steven A. Richman Eduardo Savarin, one of Facebook’s co-founders, recently announced that he renounced his U.S. citizenship in September of 2011, several months in advance of Facebook’s initial public offering (“IPO”). The resulting tax consequences (not to mention the political fallout from Washington) offer an interesting case study into the Internal Revenue [...]
Tags: International Taxation, SRichman
Authored by: Neeli G. Shah Death in the digital age is a lot more complicated than it used to be. Traditionally, fiduciaries and family members start administering an estate by reading the individual’s mail and sorting through records at the person’s home. However, with online accounts and paperless billing, these traditional approaches may not be [...]
Tags: NShah
Authored by: David L. Fox It is common for lawyers to advise their clients when setting up a professional corporation to adopt a shareholder’s agreement. Such agreements, if well prepared, will provide a road map on how to resolve disputes when they arise, and provided a means for orderly succession when one or more of [...]
Tags: DFox
Authored by: Paul J. Sowell, Esq. In a day of shrinking state coffers you would think that more and more states, in a last chance to grab revenue, would be looking to the estates of their deceased wealthy residents as a source of money. Actually, you would be wrong. The growing trend among states which [...]
Tags: PSowell
Authored by: Dorothy J. Santos One major responsibility of an estate fiduciary is to collect the assets of the estate. Normally, this process is relatively straightforward, especially if the fiduciary is knowledgeable about different types of assets and comfortable dealing with various types of financial institutions. However, there are undoubtedly times when the fiduciary has [...]
Tags: DSantos
Authored by: Scott A. Harty The U.S. government continues to levy immense pressure on the Swiss banking system, and the Swiss banks, historically renowned for their secrecy, continue to show cracks. On January 30, 2012, eight Swiss banks acquiesced to intensified pressure from the U.S. and handed over data on many U.S. clients suspected of [...]
Tags: SHarty
Authored by: Dorothy J. Santos Here’s a case for making sure you choose the right spouse and friends in life. A New York State court recently held a widow and her two friends liable in connection with the production of a “sham” Will for the widow’s deceased husband and its admission to probate. The court’s [...]
Tags: DSantos
Authored by: Scott Harty, Esq. On January 9, 2012, the IRS reopened the Offshore Voluntary Disclosure Program (the “2012 OVDP”) to U.S. taxpayers who wish to voluntarily disclose unreported offshore assets. Taxpayers wishing to participate in the 2012 OVDP must file amended returns for the years covered by the 2012 OVDP (generally the prior 8 [...]
Authored by: Neeli Shah, Esq. In light of Congress’s recent quest to find new sources of revenue and the looming changes to the estate and gift tax regimes, the time to focus on estate planning to make optimum use of current planning opportunities is now. Super-Committee On August 2, 2011, the Budget Control Act of [...]
Tags: Estate Planning, Estate Tax, Sensible Estate Tax Act 2012