Authored by: Paul J. Sowell Just when those impacted by the moving target that was the gift and estate tax exemption collectively sighed in relief at the passage of the fiscal cliff deal, it appears the celebration may have been premature. President Obama recently released his proposed budget for 2014 where he seeks to revisit [...]
Tags: Estate Tax, exemption, fiscal cliff, gift tax, GRAT, PSowell, treasury regulation, valuation discounting, wealth transfer planning
Authored by: Neeli G. Shah Many opportunistic taxpayers rushed to make year-end gifts during 2012. As a result, a record number of 2012 gift tax returns are expected to be filed in 2013. These returns were due yesterday, April 15, 2013, although the due date can be automatically extended by six months. The importance of [...]
Tags: Estate Planning, gift tax, gift tax return, NShah
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