Real estate is a common investment property for high net worth families that may include just a few properties or be leveraged in a complex manner through multiple partnerships with some trust ownership. Here is a summary of some administrative, tax and planning considerations and opportunities for clients with substantial real estate holdings. Source link

The imbalance between generation transfer (GST) tax-exempt assets and GST tax-susceptible trusts continues to grow. The much larger estate and gift tax exemption and GST exemption amounts available to taxpayers since the passage of the Tax Cuts and Jobs Act of 2017 (TCJA) have not slowed the growth of overfunded trusts vulnerable to GST taxes….

As most wealth advisors know, increases in the basic exemption amount for gift and estate tax purposes1 and the Generation Transfer Tax (GST) exemption amount.2 under the Tax Cuts and Jobs Act of 20173 (TCJA) expires on December 31, 2025.4 Although all aspects of federal estate transfer tax planning are important, GST planning for the…

Immigrants account for 15% of the wealth of America's billionaires Forbes reported in 2022,1 and the vast majority (92%) are self-made. Wealthy tech entrepreneurs continue to arrive in droves, and the United States remains the leader in foreign direct investment.2 Despite the continued growth of America's wealth and the opportunities attributed to immigrants and foreign…

Key considerations for investors. Source link

Pitfalls for clients and tips for advisers. Source link

Prior to 2023 and 2024, taxpayers faced significant challenges in challenging penalties for failing to report foreign accounts through Foreign Bank and Financial Accounts (FBAR). However, recent court decisions signal a change in the legal landscape. Despite this change, FBAR litigation remains far from straightforward. The cases discussed below share a common theme: They explore…

Congress introduced the controlled foreign corporation (CFC) rules in 1962 to prevent U.S. taxpayers from deferring federal income tax on income earned in closely held foreign companies, that is, by binding U.S. shareholders to the levels of ownership requirements to recognize certain types of income earned by CFCs regardless of whether these earnings are actually…

For several decades, there have been strong US tax reasons for holding a foreign trust offshore in order to have reduced tax friction on the trust's current earnings, thereby increasing overall family wealth outside the tax net of the USA. Unfortunately, both U.S. practitioners and beneficiaries tend to underestimate the magnitude of compounding tax savings…

Raymond James has recruited a team of five advisors to the firm's employee advisor channel. The Williamsville, NY-based group previously managed over $1 billion in client assets at Merrill Lynch. The team is led by Christopher Scott, Kevin Klein, Michael Gates and Salvatore Gandolfo and will operate as Scott Klein Gates Gandolfo Wealth Management of…