When it comes to estate and gift taxation, non-U.S. citizens face unique challenges based on their residence and domicile status. Understanding these concepts is crucial for effective estate planning and tax management.
Determining Domicile for Estate and Gift Tax Purposes
Estate and gift taxation of non-U.S. citizens is based on residence. For estate and gift
The Financial Crimes Enforcement Network (FinCEN) has adopted an interim final rule that significantly narrows the scope of beneficial ownership information (BOI) filing requirements. The interim final rule (i) removes the requirement for U.S. companies and U.S. persons to report BOI, and (ii) revises the definition of “reporting company” to mean only those entities that
Highlighted by Daniels v. Commissioner
Navigating the complexities of estate tax can be challenging, especially when determining the domicile of a taxpayer with residences in multiple states. In the recent Connecticut Superior Court case, Daniels v. Commissioner, the court faced the intricate task of establishing the domicile of a wealthy individual who divided his
FinCEN announced on February 27 that it will not enforce the current reporting deadline of March 21 under the Corporate Transparency Act (CTA). FinCEN will not issue any fines or penalties or take any other enforcement action against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to
A federal district court judge in Texas signed an order on February 17 lifting the last remaining nationwide injunction blocking beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA).
The Financial Crimes Enforcement Network (FinCEN) enforces BOI requirements and has promised a 30-day filing delay to allow reporting companies to comply. On February
GRATs Allow Transfer of Wealth Outside Your Estate With Minimal or No Gift Tax
Now is a good time to consider wealth transfer strategies that remove assets from your taxable estate. A common strategy is a grantor retained annuity trust, commonly referred to as a GRAT.
Description. A GRAT is a strategy that freezes the
In a dramatic turn of events, a Fifth Circuit panel has reinstated the nationwide injunction blocking enforcement of the Corporate Transparency Act (the “CTA”) just three days after a separate panel of the Fifth Circuit had lifted it.
Thus, for now, reporting companies once again are not required to submit Beneficial Ownership Information Reports by
The nationwide injunction enjoining the Corporate Transparency Act (the “CTA”) was lifted by order of the United States Court of Appeals for the Fifth Circuit on December 23, 2024. This ruling notably impacts reporting companies subject to the CTA that were formed prior to 2024 and which were facing a January 1, 2025 deadline to
As the new year approaches, we present our annual year-end advisory for 2024. This edition highlights noteworthy estate and gift tax changes and outlines planning opportunities for year-end and beyond. We also take a moment to recognize some of our accomplishments in 2024 and provide our outlook for the new year.
Enforcement of the Corporate Transparency Act (the “CTA”) and its implementing regulations (referred to herein as the “Reporting Rule”) – which require certain business entities formed or registered to do business in the United States (referred to herein as “reporting companies”) to report beneficial ownership information to the Treasury Department – was preliminarily blocked nationwide