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Welcome to Lost in Translation: Blunders in International Estate Planning; in this blog series, I will delve into the rarified world of international estate planning, shedding light on possible pitfalls and slip-ups. Blunder...more
It has been back to business as usual for the Internal Revenue Service (IRS) and Department of the Treasury in 2024. US tax authorities are not shaking up the international private client landscape, but instead are providing...more
Welcome to “Lost in Translation: Blunders in International Estate Planning.” This blog series explores the rarified world of international estate planning, uncovering potential pitfalls and providing insights to navigate the...more
Unlike most countries in the world, if you are a citizen or resident of the United States, the government gets to tax all of your worldwide income, regardless of where it's earned or where you live. And if the IRS decides...more
It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more
Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...more
In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more
In my previous post, I discussed some of the relevant U.S. federal tax implications to consider when a foreign individual makes a gift of cash to a U.S. person. That discussion assumed that the gift was coming directly from...more
Astrid Owen leads this interactive webinar to discuss the US taxation of US beneficiaries and US settlors of non-US trusts. The benefit of using non-US grantor trusts established by a non-US person for US beneficiaries...more
Revocable trusts are a ubiquitous part of modern US estate planning because they avoid the delay, cost and publicity inherent in probate administration and, in the international context, because of the certainty they provide...more
Protecting family assets in the event of a divorce is particularly significant for family business owners, who typically want to avoid sharing ownership with their ex-spouses or their children’s ex-spouses. A prenuptial...more