Asset Protection

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Monday, 09 December 2024 11:55

SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

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

In Moore v. U.S. (36 F. 4th 930), the U.S. Supreme Court ruled on a constitutional challenge of IRC section 965, the mandatory repatriation tax (MRT).

Published in Publications

Friday, 04 October 2024 11:47

Pre-Immigration Planning and the Foreign Trust

Article Written for: Florida CPA Today Magazine, FICPA Florida Institute of Certified Public Accountants

For U.S. income tax purposes, foreign trusts are treated as non-resident/non-citizens (NRNC), subject to U.S. income tax only on U.S. source income.^[1]

Published in Publications

Wednesday, 16 October 2024 00:00

Gary covers LLCs, trust cases, SCOTUS tax rulings, exposures, and strategies to limit IRS power, in his seminar: "Tax Planning and Asset Protection Update (including 2024 U.S. Supreme Court Decisions)" via Live National Webinar

Tax Planning and Asset Protection Update (including 2024 U.S. Supreme Court Decisions)

In this seminar, we discuss both (i) the LLC and trust cases that govern protective structuring and (ii) the three 2024 SCOTUS cases that shape tax policy in the U.S. Attendees will learn about new exposures and insulating strategies (both domestic and international) as well as the limits on IRS power.

Wednesday, October 16th @ 12 Noon ET
Register for this LIVE (no cost) seminar.

Published in Press Releases

Monday, 04 March 2024 19:00

Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax

Article Written for: Florida Bar Journal

A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to U.S. income tax only on U.S. source income.^[1]

Published in Publications

Wednesday, 06 March 2024 19:00

Gary presents for National Business Institute's LLC Rules Changes Guide 2024 Program. He discusses U.S. court rulings on entity and trust protections across multiple jurisdictions, in his seminar, "Asset Protection and the Latest State Case Law."

Asset Protection and the Latest State Case Law

In this seminar, we discuss how U.S. courts have ruled on entity and trust protections in the various jurisdictions. This section of the "LLC Rules Changes Guide 2024" program will equip attendees with the knowledge necessary to update appliable asset protection techniques and structures.

Wednesday, March 6th @ 2 PM ET
Visit the National Business Institute website for more information.

Published in Press Releases

Monday, 05 February 2024 19:00

Gary presents for the Single-Member LLCs: Attorneys' Guide program an overview of legal traps and hazards potentially hindering asset protection strategies, in his seminar: "Asset Protection Pitfalls" for the National Business Institute.

Asset Protection Pitfalls

In this seminar, we discuss how advisors and clients have unintentionally undermined asset protection strategies, both domestic and foreign. Attendees will learn about current cases and how to avoid weakening protective structures.

Tuesday, February 6th @ 12:45 PM ET
Visit the National Business Institute website for more information.

Published in Press Releases

Monday, 13 November 2023 08:46

Foreign Trusts: Income Tax and the Nonresident Noncitizen Grantor

Article Written for: the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants

Foreign trusts generally incur taxable income similar to nonresident noncitizen (NRNC) individuals, with certain limitations on credits and deductions that are source income.¹

Published in Publications

Tuesday, 28 November 2023 19:00

Gary and Brian present for the Estate Planning Council of Naples, discussing offshore structures, tax strategies, and best practices in asset protection, in their seminar: "Foreign Asset Protection and Tax Planning."

Foreign Asset Protection and Tax Planning

In this seminar, we discuss protective offshore structures and related tax strategies. Attendees will learn how best to establish and fund foreign trusts and business entities while maintaining U.S. tax efficiency. The advantages of offshore vs. domestic trust planning will also be discussed. Topics will include choosing jurisdictions, choice of governing law, expatriation, and pre-immigration planning.

Wednesday, November 29th @ 12 Noon ET
Visit the Estate Planning Council of Naples website for more information.

Published in Press Releases

Thursday, 19 October 2023 20:00

Gary explains how to best choose and implement the use of LLCs in protective structuring in his seminar, "Structuring and Funding the LLC: Advanced Asset Protection Strategies" for the National Business Institute.

Structuring and Funding the LLC: Advanced Asset Protection Strategies

In this seminar, we explore advanced asset protection strategies, including the protective aspects of LLCs and how to best combine the LLC with domestic and offshore asset protection trusts. We cover legal cases, domestic vs. foreign options, and the keys to effectiveness. This seminar is ideal for financial and legal professionals.

Friday, October 20th @ 11 AM ET
Visit the National Business Institute website for more information.

Published in Press Releases

Sunday, 24 September 2023 20:00

Gary explores partnership tax considerations for family structures, asset protection, jurisdiction choices, and trust strategies in his seminar, "Family Limited Partnerships in Estate Planning Program" for the National Business Institute.

Family Limited Partnerships in Estate Planning Program

In this seminar, we explore a wide range of topics raised by the family investment structure. Included in the discussion will be estate and gift tax strategies, distribution and basis issues and how to best protect partnership assets for generations. Attendees will gain insight into selecting the right jurisdiction and how to blend partnership and trust strategies (foreign and domestic). Discussion includes nuances like partnership tax classification and "S" status for family businesses.

Monday, September 25th @ 2 PM ET
Visit the National Business Institute website for more information.

Published in Press Releases

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Our mission is to serve as a resource for complex domestic and international business transactions, tax, health law, asset protection, and related litigation.

Our firm is an approachable and economic alternative to large national and international law firms. Se habla español.

Eric hosts an interactive Q&A to share negotiation strategies and conflict resolution techniques: "Negotiation and Mediation Q&A: Handling Difficult Situations Professionally and Ethically" via Live National Webinar

11 December 2024

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Orlando (Maitland), Florida 32751

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Office hours: Open weekdays
from 8:30 AM to 5:30 PM

Seminar Videos

SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

Pre-Immigration Planning and the Foreign Trust

Gary covers LLCs, trust cases, SCOTUS tax rulings, exposures, and strategies to limit IRS power, in his seminar: "Tax Planning and Asset Protection Update (including 2024 U.S. Supreme Court Decisions)" via Live National Webinar

Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax

Gary presents for National Business Institute's LLC Rules Changes Guide 2024 Program. He discusses U.S. court rulings on entity and trust protections across multiple jurisdictions, in his seminar, "Asset Protection and the Latest State Case Law."

Gary presents for the Single-Member LLCs: Attorneys' Guide program an overview of legal traps and hazards potentially hindering asset protection strategies, in his seminar: "Asset Protection Pitfalls" for the National Business Institute.

Foreign Trusts: Income Tax and the Nonresident Noncitizen Grantor

Gary and Brian present for the Estate Planning Council of Naples, discussing offshore structures, tax strategies, and best practices in asset protection, in their seminar: "Foreign Asset Protection and Tax Planning."

Gary explains how to best choose and implement the use of LLCs in protective structuring in his seminar, "Structuring and Funding the LLC: Advanced Asset Protection Strategies" for the National Business Institute.

Gary explores partnership tax considerations for family structures, asset protection, jurisdiction choices, and trust strategies in his seminar, "Family Limited Partnerships in Estate Planning Program" for the National Business Institute.

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