International Law Archive
The HIRE Act
The Hiring Incentives to Restore Employment Act (the HIRE Act)1 of 2010, found in Internal Revenue Code Section 6038D, enacted foreign asset disclosure...
2011: A Time to Hunker Down
As we begin 2012, certain global concerns from 2011 continue to resonate. We're still dealing with an: uncertain global economy, with a focus on the troublesome...
Unconventional Wisdom
From an international perspective, family businesses in the Gulf region are taking new approaches to succession. In five areas, some leading Gulf families...
Unpredictable Treatment
As the world appears to shrink, more people acquire property in multiple jurisdictions or have family members living in different countries. Residents...
Defending Offshore Trusts From Foreign Attack
Trustees sometimes find themselves staring down the barrel of the litigation gun, whether as the target, or, more typically, as a neutral party standing...
The Accidental American
Too often, people who live outside the United States and are citizens of other countries discover that they're U.S. citizens as well and, therefore, owe...
Around the World in 2010
Ignited by the global financial crisis in 2010, many wanted to know, Where's the money? Who owns it? How can our country get more? and Where are the super-rich...
Offshore Asset Protection Trusts
The death of the offshore asset protection trust has, by some, been greatly exaggerated.1 In recent years, attacks on a few such trusts under extreme...
European Harmonization
Every country1 in the European Union (EU) has its own laws and traditions for inheritances. This presents a problem when someone dies with assets in more...
Bringing It Home
Planning for an existing foreign non-grantor trust that has one or more U.S. beneficiaries presents complex challenges for trustees and professional advisors....
The Real Allure of Emerging Markets
The conventional investment wisdom of going where the growth is would suggest increasing equity allocations to emerging markets. But our research shows...
Is 2009 the Year That Bank Secrecy Died?
The IRS' success against UBS AG seems to be the famed butterfly in the rainforest that causes gigantic ripples across the world. The campaign against...
Gift Tax Cost Depends On Form and Substance
When it comes to the tax cost of a lifetime gift of property, estate planners often focus on the gift taxable value of the transferred asset and, to that...
Do Your Clients Still Have Hidden Foreign Accounts?
The events of the past year make it clear that the U.S. government has launched an unprecedented assault on taxpayers who hide their assets in offshore...
FBAR Problems And Proposed Solutions
The Internal Revenue Service's recent efforts to enforce the reporting of foreign bank accounts has created a lot of confusion for many people. This is...
What's a Fideicomiso?
Any professional who serves high-net-worth clients eventually comes face to face with a Mexican fideicomiso (pronounced fee-day-kah-mee-so)...
The Rest of the World
Clients are often more global than their U.S. advisors. But we can change that. Here are some key trends in trusts and estates internationally: Trusts...
Death Taxes Around the World
Next year, no matter how preoccupied the federal government is and no matter who is president, a new federal estate tax law is quite likely to be adopted....
When U.S. Clients Receive Money From Foreign Family Members
Many clients think the foreign trust tax and reporting rules can be circumvented by using non-U.S. persons as nominees. But the United States has rules...
Fleece the Fleeing
Giving up a U.S. passport carries a hefty new price tag. A new law subjects certain individuals who expatriate or give up their green cards to immediate...
Des Americains en France
Thomas Jefferson did it in the 1790s. Ernest Hemingway did it and wrote about it in the 1920s. Today, as well, many Americans move to France to live....
NEW U.S.-FRENCH TREATY PROTOCOLS
Carolyn DeVore of Pullman & Comley, LLC, in Westport, Conn., reports: The United States and France ratified significant protocols to their income tax...
Foreign Reporting: Get It Right
As estate planners, we love helping people, and as attorneys, we need to bill hours. So when we can help people and bill hours at the same time, you'd...
You Must Remember This
With the accelerating globalization of economic relations and the compression of travel and communication distances between countries, increasing numbers...
Inheriting from Abroad
Over the years, planners have found several techniques useful in helping non-U.S. families pass wealth to the next generation: offshore personal investment...
Nonresident Aliens
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...
Just Off the Boat, Trust Fund in Hand
Many wealthy people today spend substantial amounts of time in various countries and many may eventually find themselves becoming tax residents of the...
OFFSHORE TRUSTS: CROSSING THE TS
Offshore trusts are popular estate-planning tools for a various reasons, especially legal impunity. Some offshore jurisdictions don't recognize foreign...
Come to America
Once, it was common to advise international clients to set up their tax-free trusts in one of the offshore tax havens places with sun-kissed beaches and...
