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Sunday, 26 June 2022 20:00

Careful with Asset Protection Transfers: Courts May View Them as Fraudulent

Careful with Asset Protection Transfers: Courts May View Them as Fraudulent

Article Written for:  the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants 
An effective asset protection plan must be implemented before any foreseeable clams, as existing debts and anticipated liabilities are not avoidable. Reactionary transfers (made to avoid a present or future creditor) are reversible.

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Wednesday, 08 June 2022 20:00

Using the Foreign Corporation to Avoid Estate Tax

Using the Foreign Corporation to Avoid Estate Tax

Article Written for:  the MassCPA's Massachusetts Society of CPAs 
All U.S. situs assets held by a non-resident non-citizen (NRNC), both tangible and intangible, unless falling within a limited exemption, are subject to the U.S. estate tax. Those same assets held in a foreign corporation are excluded from estate tax.

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Saturday, 30 April 2022 20:00

Estate Tax Planning for NRNCs Using the Foreign Corporation

Estate Tax Planning for NRNCs Using the Foreign Corporation

Article Written for:  TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

Shifting Assets from U.S. SITUS

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Monday, 28 February 2022 19:00

The Non-Citizen and the U.S. Estate and Gift Tax – An Introduction

The Non-Citizen and the U.S. Estate and Gift Tax – An Introduction

Article Written for:  TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

This month, we introduce our series on international tax law.  We start with an introduction to the international aspects of the U.S. estate tax and the gift tax.

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Thursday, 16 December 2021 21:00

Expatriation from the United States, Part 2: The Inheritance Tax

Expatriation from the United States, Part 2: The Inheritance Tax

Article Written for:  Florida CPA Today, a publication by the Florida Institute of CPAs

In addition to the Exit Tax, the Heart Act added a new federal transfer tax, which imposes an "Inheritance" tax on certain gifts or bequests (testamentary dispositions) made by a "covered expatriate" to U.S. recipients. This is the second article in our two-part series on the expatriation tax.

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Thursday, 16 December 2021 20:00

Expatriation from the United States, Part 1: The Exit Tax

Expatriation from the United States, Part 1: The Exit Tax

Article Written for:  Florida CPA Today, a publication by the Florida Institute of CPAs

Abandonment of United States citizenship or long-term residency (by non-citizens) may trigger the United States “expatriation tax”. The expatriation tax consists of the “Exit Tax” and the “Inheritance Tax.” In this first of our two-part series, we explain the Exit Tax.

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Wednesday, 01 December 2021 09:42

Modern Asset Protection – An Introduction

Modern Asset Protection – An Introduction

Article Written for:  TaxStringer, the NYSSCPA's publication for tax topics

Asset protection is a body of law that has developed as an amalgamation of business structures, trusts, titling and creditor exemptions. Asset protection planning insulates assets otherwise exposed to future unknown creditors. Prudent structuring uses widely accepted legal strategies to make clients unattractive to claimants.

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Saturday, 31 October 2020 20:00

Expatriation from the United States: The Exit Tax

Expatriation from the United States: The Exit Tax

Article Written for:  Florida Bar Journal

Abandonment of U.S. citizenship or long-term residency (by non-citizens) may trigger U.S. income tax. The “expatriation tax” consists of two components: the “exit tax” and the “inheritance tax.” Both may be triggered upon abandonment of citizenship or (for non-citizens) abandonment of a green card by a long-term resident. In this first of our two-part series, we explain some of the principal terms of the exit tax.

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