Content Type




Estate and Gift tax Situs of Assets – Specific Examples

December 10, 2020

The first part of this series summarized basic US gift and estate tax situs rules and how the gift and estate taxes are applied to individuals who are not US…

Estate and Gift Tax Situs of Assets – Basic Rules

December 3, 2020

Individuals who are not US citizens and are not domiciled in the United States for transfer tax purposes (non-resident aliens) are subject to US gift tax only on gifts of…


UK-US Tax Planning: Trusts, Residential Real Estate, and Real Estate Investment Planning

September 29, 2020

Discusses the complexities of UK-US tax planning while considering the application of income, gift, and estate tax regimes on various structures. Topics include: Advising trustees of offshore trusts – with…

US Individuals Investing in Foreign Companies Should Consider a Section 962 Election to Reduce the GILTI Tax Burden

September 3, 2020

Updates and further considerations to the uses of a Section 962 Election in scenarios where U.S. income tax residents invest in, or retain, ownership over their non-U.S. corporations. International Law…


The Complete Family Office: A Guide for Affluent Families and the Advisors Who Serve Them

July 1, 2020

Miles Padgett and Don Kozusko have produced a chapter for the upcoming book, The Complete Family Office: A Guide for Affluent Families and the Advisors Who Serve Them, 2nd Edition…


Panelist, “Tax Residency in the Coronavirus Era”, STEP USA/STEP Israel, 30 June 2020

June 30, 2020

Stan Barg is a Panelist on “Tax Residency in the Coronavirus Era” at STEP USA/STEP Israel, 30 June, 2020.…

Completing US Tax Forms: Form 5472 – Foreign-Owned Disregarded Entities

June 18, 2020

A limited liability company (LLC) that is created under the laws of a US state and wholly owned by a single non-US person (a foreign-owned LLC) is required to report…


The Modification of Irrevocable Trusts

May 1, 2020

Amanda C. Andrews gives a joint presentation regarding the modification of irrevocable trusts at the 63rd Annual Estate Planning Short Course of the Illinois Institute of Continuing Legal Education. May…


PPP: Small Business Loan Warning Doesn’t Get to Heart of the Issue

April 24, 2020

Severiano E. Ortiz is quoted in this article about the Paycheck Protection Program (PPP). In this article, he addresses the lack of rule clarity regarding businesses that are backed by…

Time again to File Bureau of Economic Analysis Survey Form BE-10 to Report Investments Abroad

April 23, 2020

Using Form BE-10, the Bureau of Economic Analysis (BEA) conducts a survey on US direct investment abroad. The survey is conducted every five years and currently covers fiscal years ending…