Over the years, planners have found several techniques useful in helping non-U.S. families pass wealth to the next generation: offshore personal investment companies (PICs), settlor-directed revocable trusts, controlled foundations, irrevocable...
The gross estate of a nonresident alien1 (NRA) is determined in the same manner as the gross estate of a U.S. resident or citizen, although it's generally limited to property situated, or deemed to be situated in the United States at the time of...
The enactment of Internal Revenue Code Section 27021 in 1990 sounded a virtual death knell for the grantor retained income trust (GRIT). The GRIT fell into disuse, so much so that it is often overlooked even in the few circumstances that its use...
Many wealthy people today spend substantial amounts of time in various countries and many may eventually find themselves becoming tax residents of the United States. So U.S. trusts and estates practitioners shouldn't be surprised if a client...
Private foundations in the United States donated about $1.38 billion in grants to individuals in the last five years.1 But extensive regulatory requirements governing grants to individuals mean that such largess should be accomplished cautiously...