Although the grantor retained annuity trust (GRAT) is an excellent estate-planning technique, it can be complicated to create, depending upon the client and assets involved. Hard-to-move assets can mean problems. Questions about when the GRAT is...
Offshore planning has gotten a lot of bad press lately.1 It's getting slammed in the U.S. Senate. This August, a Senate subcommittee held a week-long hearing on its report, Tax Haven Abuses: The Enablers, the Tools and Secrecy2 that purported to...
In The Curmudgeon's Guide To Practicing Law, author Mark Herrmann points out that You cannot answer a legal question without knowing the context in which it is posed. You must therefore be sure to understand the context of all the work that you...
Perhaps no estate-planning tool is more subject to the law of unintended consequences than the ubiquitous Crummey1 power. But, although there can be estate, gift and generation-skipping transfer (GST) tax consequences, it's the income tax impact...
There's some good news in the ongoing war with the Internal Revenue Service over family limited partnership (FLP) discounts: IRS agents are settling practically all of the cases and even most of the ones. That means it pays to know how to...
As Election Day 2006 approaches, state politicians increasingly set their sights on a familiar political enemy: taxes. While all taxes make popular targets, this year state estate taxes are attracting heightened attention. In her state-of-the...
The Organisation for Economic Co-operation and Development (OECD) has released a seminal report on tax information collection and exchange practices in 82 countries. The principal achievement of this long-awaited report, Tax-Cooperation Towards a...