What is a foreign grantor trust (“FGT”). A FGT is typically used when a non-U.S. Person individual (i.e., an individual who is a non-U.S. citizen, not a “green card” holder, or otherwise not considered a
If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, exceeding certain thresholds, the
Insert a no-contest clause When a will contest seems likely, an in terrorem clause may be beneficial. An in terrorem clause, also known as a “no-contest” clause, generally provides that a bequest will fail if
The Internal Revenue Service’s efforts to prod taxpayers to disclose their offshore bank accounts and pay taxes on their holdings have reached the $10 billion mark and prompted over 100,000 taxpayers to come forward, the
Earlier this month, on October 14, 2016, New Jersey Governor Chris Christie signed into law that increased the NJ Estate Tax exemption from $675,000 to $2 million for deaths in 2017, and fully eliminated the
The cost of compliance for many people is growing. Those U.S. persons with bank accounts in foreign jurisdictions who have yet to come into compliance with U.S. tax filing requirements have very little time. In
Last week, the New Jersey legislature announced its plan to repeal estate tax by January 2018. The New Jersey estate tax is presently one of the highest in the nation. For state residents the estate
IRS has recently released a new International Practice Unit (IPU) providing guidance to its examiners on the monetary penalties applicable if certain categories of U.S. shareholders fail to comply with the reporting requirements on Form
An audit reconsideration is defined by the Internal Revenue Manual (IRM) as: the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax
The IRS has tightened its enforcement of the Foreign Account Tax Compliance Act (“FATCA”). FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions
Last week Trinidad and Tobago and the United States signed an agreement to facilitate automatic exchange of information under the US Foreign Account Tax Compliance Act (FATCA). FATCA, enacted by the US Congress in 2010,
Proceeds from a settlement involving an employment-related discrimination case may be taxable to the employee under some circumstances and not taxable in others. Non-taxable settlement amounts: Medical expenses associated with medical distress; Emotional distress,
