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Revenue Procedure 2005-241 published April 18, 2005 and effective as of March 30, 2005 is among the most controversial rulings promulgated by the Internal Revenue Service in recent memory. It has been roundly criticized by estate planners and...
Baby boomers are intent on getting the most out of life and their money for many years to come. Whether they will or not, though, is far from guaranteed. What does this demographic really need and what does that mean for your practice? What to...
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...
Peter Jennings, the longtime ABC News anchorman born in Canada, wound up living the American dream and dying with an estate worth in excess of $50 million, according to the probate petition filed late September with the New York County Surrogate's...
With the accelerating globalization of economic relations and the compression of travel and communication distances between countries, increasing numbers of U.S. citizens and residents find themselves holding property in jurisdictions outside the...
From David A. Handler, partner in the Chicago office of Kirkland & Ellis LLP, we have this report: Transfer restrictions in a family limited partnership agreement are disregarded In Estate of Sidney E. Smith III v. United States, No. 02-264 Erie ...