Content Type




Reporting Deadlines Draw Near

April 10, 2003

April 15 marks the filing due date not only for US income tax returns, but also for the reporting of foreign gifts, distributions from foreign trusts and income earned in…


Overview of US Tax and Reporting System

March 13, 2003

US citizens and non-citizens who are resident in the United States are subject to US gift and estate tax on their worldwide assets, and to US income tax on their…


Private Trust and Protector Companies: How Much Family Control?

October 1, 2002

When choosing trustees, wealthy U.S. families traditionally selected from among their own family members and those advisors or commercial trustees with whom they had a professional or business relationship over…


Mellon Bank, Fiduciary Expenses, and the 2% Floor

January 1, 2001

Miles Padgett authors, “Mellon Bank, Fiduciary Expenses, and the 2% Floor,” for Estate, Gifts and Trust Journal, January 2001.…


Respect for “Form” as “Substance” in U.S. Taxation of International Trusts

December 1, 1999

It would be difficult to imagine how the federal tax system of the United States could function without the “substance over form” principle. December 1999. Download…