The typical family office has a sophisticated tax structure that must blend income tax planning with estate tax planning. The structure typically involves a number of business entities that will include owners involving individuals and one or more dynasty trusts for efficient estate and gift tax planning. […]
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U.S. citizens and U.S. tax residents (“U.S. Persons”) who reside outside the U.S may have investments or assets that require special reporting or have alternative tax regimes. It is important the U.S. Person or their tax advisor understands these specialized tax rules in order to avoid punitive tax regimes or penalties to properly file the required informational reports. […]
The government does not annually tax wealth. However, the IRS wants to know about funds U.S. Persons have in foreign bank accounts. There are now two different reporting requirements for foreign bank accounts, the Foreign Bank Account Report (“FBAR”) and the individual reporting requirement under the Foreign Account Tax Compliance Act (“FATCA”). […]
U.S. citizens and U.S. tax residents (“U.S. Persons”) are taxed in the United States on their worldwide income no matter where in the world they reside. The U.S. taxes based on citizenship, which is different than almost all other countries in the world that tax based on residence.
This often catches U.S. Persons who have never lived in the U.S. or have lived abroad for a number years by surprise. Any U.S. Person living abroad with income for tax year 2023 above the following thresholds must file a U.S. tax return: […]
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Recently we were transitioning to take over the tax filing for an executive who was a U.S. tax resident because he had a green card but resided outside the U.S. This executive has considerable income and the country that he resided in also taxed at higher rates than the U.S. federal income tax rates. Our review of the executive’s tax return not only found there were informational reporting errors, but that the income of the executive had been over reported by more than $160,000 […]
In the acquisition of a business, it is important the buyer has a clear understanding of the target’s financial, commercial, operational, technical, human capital, and tax condition. Too often, certain parts of the due diligence do not receive the attention required, either because the firm performing the due diligence does not have the necessary background, or there is a lack of coordination among professionals in different fields of expertise. This is a critical opportunity for the buyer to learn of issues with the target as the nonidentification of key issues will have a financial impact down the road for the buyer. […]
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