Strangi's Stranglehold On Offshore PlanningStrangi's Stranglehold On Offshore Planning
In the months since the Tax Court's decision in Estate of Strangi v. Commissioner (Strangi II) much has been written about its impact on estate planning, especially using family investment entities. But none of the literature discusses the implications for offshore families who invest in the United States. Yet Strangi II and, more importantly, the trend it represents might be one of the most important
Edward J. Finley II, vice president, JPMorgan Private Bank, New York, N.Y.
In the months since the Tax Court's decision in Estate of Strangi v. Commissioner (Strangi II) much has been written about its impact on estate planning, especially using family investment entities. But none of the literature discusses the implications for offshore families who invest in the United States. Yet Strangi II — and, more importantly, the trend it represents — might be one of the most important developments in offshore planning in years.
As those who advise offshore families well know, the personal holding company (PHC) is a mainstay for these families. Typically, a matriarch capitalizes a company located in an offshore financial center (such as The Baham...
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