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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, Managing Director and Private Client Advisor

February 1, 2004

18 Min Read
Wealth Management logo in a gray background | Wealth Management

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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About the Author

Edward J. Finley II

Managing Director and Private Client Advisor, U.S. Trust, Bank of America Private Wealth Management

Edward Finley is a Managing Director and Private Client Advisor with U.S. Trust, Bank of America Private Wealth Management, in New York. Ed leads the design and development of tailored financial strategies for a select group of families, endowments, and foundations. He orchestrates thoughtful initiatives in investment management, trust and estate planning services, wealth strategy, family office services, banking, and philanthropy, integrating the insights and experience of a team of in-house specialists. As the lead relationship manager, Ed works closely with clients to facilitate informed decision-making and active stewardship of wealth.

Ed has worked in wealth management since 1991. Prior to joining U.S. Trust, Ed spent thirteen years with J.P. Morgan Private Bank in New York, where he was a Managing Director and Senior Banker consulting to high net worth families, closely held businesses, charitable foundations and non-governmental organizations. He began his career practicing law with Milbank, Tweed, Hadley & McCloy, and Kirkland & Ellis, where he focused on domestic and international trust and estate planning services. His career also includes a tenure with Coblentz, Patch, Duffy & Bass LLP, where he advised families on wealth strategy and estate administration.

Ed is an adjunct Professor at the University of Virginia, McIntire School of Commerce, where he teaches the advanced quantitative finance seminar in investment management. He is a frequent lecturer and author on wealth management issues and serves on the editorial board of Trusts & Estates  magazine.

Ed earned his B.A. from the University of Virginia and his J.D. from the University of Chicago.* He lives in New York City with his husband and two children.

*In his role at U.S. Trust, Ed does not provide legal advice.