Jack Townsend has — as usual — a thoughtful analysis of the implications of the UBS settlement in which UBS will cough up a few thousand names of U.S. taxpayers. (Exact details of the settlement haven’t been publicized yet.) It seems clear to me (and to Mr. Townsend) that the settlement depends on the Swiss [...]
This is a little bit of inside baseball for the pointy-headed trust aficionados among you. We draft tons of trusts. Domestic trusts. Foreign trusts. Revocable and irrevocable. There is plenty of stuff in a trust that is non-obvious, both in the trust language and the tax implications of what you do after the trust is [...]
A cautionary morality play for the wiser ones of you in the audience. I get many people coming into the office asking for help. They have (or want to have) money in offshore accounts, foreign trusts, corporations, what have you. Some of them say “Well, how will the IRS ever find out?” (Meaning “Can I [...]
To the people who attended my course today in San Jose on Foreign Trusts — find Notice 2008-63 as a PDF or Notice 2008-63 as HTML on the IRS website. This is all about private trust companies, in response to Lee Kaplan’s question.
A reader of my November, 2008 article in California CPA Magazine (hi, David) called me and asked a question about the article. He wanted to clarify a generation-skipping transfer tax question. I didn’t have the space in the article to cover all of the nooks and crannies on the subject of estate taxation for cross-border [...]
