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• Expatriation! Why and Why Not!!!

  The headline news that a co-founder of Facebook has given up his U.S. citizenship to avoid income and estate tax may trigger a lot of interest in expatriation. Some people will read the news of the expatriation of Mr. Sevarin as validating expatriation for tax purposes. The process of giving up U.S. citizenship has several [...]

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• Why Asset Protection Trusts May Fail

  In a recent federal income tax collection case, the trial court discusses the reasons why an asset protection trust failed to protect assets of a taxpayer from a tax levy. The court in Evseroff found that all the assets of an irrevocable trust were subject to collection by the IRS for the tax liability of [...]

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• Minimize Estate Tax on Foreign Assets

  A recent U.S. Tax Court case provides a road map to minimize estate tax liability. In Wandry v. Commissioner the Tax Court held that a gift of an interest in a closely held business that was defined by dollar amount rather than percentage interest could successfully limit the tax consequences of the gift. The case [...]

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• Estate and Gift Tax Trap for Owners of Foreign Assets

  The Congressional Research Service (CRS) just published an analysis of the effect of extending the “Bush”tax cuts. Included in the expiring tax cuts are estate and gift tax rate cuts. If the tax cuts are allowed to expire then the estate tax will go from an exemption equivalent of $5,000,000 and a top bracket of [...]

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