In a previous Wiggin and Dana LLP advisory, we addressed what constitutes a “foreign trust” under the Internal Revenue Code (IRC).[1] We now explore the tax consequences of a foreign trust, as well as the differences between a foreign grantor trust and a foreign non-grantor trust.
There are many benefits of having
Overview
Individuals who are neither United States citizens nor U.S. “domiciled” (U.S. resident with an intention to remain indefinitely in the U.S.) are subject to a less favorable estate tax planning environment. In 2024, individuals who are U.S. citizens and domiciliaries can transfer $13,610,000 free of estate, gift and GST tax during their lives or
As we wrap up 2023, let us take a look back at some of the important estate planning topics that were discussed throughout the year. Our Partners Erin Nicholls and Michael Clear and their distinguished guests shared their expertise on a wide range of subjects, including Using Trusts for Your Beneficiaries, SLATs, Estate
Following up on a prior advisory that we published on “Estate Tax Planning and the Often-Overlooked Power of the ‘Med-Ed Exclusion’” (click here to read), we offer this update and a deeper dive into the gift of medical care that may have meaningful implications on estate planning strategies for many individuals.
First, by
The reporting requirements under the Corporate Transparency Act (CTA) will come into effect on January 1, 2024. The U.S. Treasury estimates that more than 32 million pre-existing entities and approximately 5 million new reporting companies annually over the next decade will have to register under the CTA.
The CTA was enacted on January 1, 2021
Originally published on February 11, 2021.
The Corporate Transparency Act (CTA) was enacted on January 1, 2021 as part of the National Defense Authorization Act creating a federal beneficial ownership registry applicable to corporations, limited liability companies (LLCs) and most partnerships. Targeted at small, privately-held business entities, the CTA requires these organizations to report
There has been a longstanding effort globally and a lot of pressure on the United States to implement some sort of registry on a federal level for ownership of small and mid-sized entities. On today’s episode of “Future Focused: Sophisticated Estate Planning,” Partners Erin Nicholls and Michael Clear chat with Partner Carolyn Reers about the
Our world today is more interconnected than ever before, and our clients are increasingly living, working, and investing across borders. That interconnectivity can create risks for trusts. If a trust is deemed a “foreign trust” for U.S. federal tax purposes, that can cause unintended and adverse tax consequences for both the grantor (creator) of the