Tag Archives: IRS

Charitable Remainder Trust Problems

02 Dec
Charitable Remainder Trust

Charitable Remainder Trust Overview: 1) Trust status cannot extend to beneficiaries and participants The point for all to grasp is that whatever the legal, juridical and tax status of funding structures, that status cannot extend to beneficiaries and participants as individuals. That is why a trust is quite useless to beneficiaries and participants. Besides it […]

Top 3 Immediate Considerations for Wealth Transfer Valuation Discounting from McManus & Associates

21 Sep
Abstract image of ice and fire to depict wealth transfer valuation discounting

Recently proposed IRS regulations mean discounting opportunities could expire by year-end, explains top-rated tax and estate planning attorney  NEW YORK, NY – September 21, 2016 – Proposed Internal Revenue Service (IRS) regulations were recently issued that would eliminate discounting opportunities related to wealth transfer planning. McManus & Associates, a top-rated estate planning law firm with […]

Broken Dreams – How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants – Part 1

19 Sep
Lady Liberty immigrants

The U.S. Presidential Elections have shifted into overdrive with both the Republican and Democratic holding their conventions over the next two weeks to select Donald Trump and Hillary Clinton as their party’s candidates respectively.  Viewed in tandem with Britain’s departure from the European Union and recent acts of terrorism in France and Belgium, the political […]

Double Down! – Inter-Generational Split Dollar Throws Sand in the Face of the IRS Again

14 Aug
friends toasting the IRS with champagne flute on beach at sunset

Recently I wrote an article on JD Supra called Split to Be Tied (May 4, 2016) regarding the Tax Court decision in Estate of Morrissette, (Estate of Clara M. Morrissette v. Commissioner, 146 T.C. No. 11 (April 13, 2016)). Once again, the IRS has lost a significant inter-generational split dollar case – Estate of Marion Levine, Deceased v. […]

My “Flippín” House?

23 Jun
House flppers

Tax Strategies to Reduce Taxation and Build Wealth for House Flippers I seem to be perpetually out to lunch. When I step on the scale too, this point is further confirmed. I do not know why I have waited so long to write an article for the benefit of real estate investors who “flip” houses. […]

Malta U.S. Pension Scheme Review

15 Jun
Malta U.S. Pension Scheme

If we wrote a book about the Malta U.S. Pension Scheme it would be about 12 pages even if we covered everything imaginable in great detail…otherwise it would be a couple of paragraphs and not worthy of a white paper because it is NOT an occupational retirement plan it is a life time annuity with […]

Private Label Trust

13 Jun
Private Label Trust

We provide clients with a private label trust platform that is consolidated international occupational retirement law and is government regulated, registered and recognized in over 130 countries. A Fairbrook Alliance Private Label Trust is not a tax haven, insurance product or company, or personal trust; it is a globally-recognized occupational retirement plan providing far greater […]

The Trend in Chinese Offshore Investment

18 Apr
Chinese offshore investment

The trend in Chinese offshore investment in the U.S. has been increasing each year. In 2012 the level of investment was $6.5 billion. Much of this investment is in U.S. real estate where great buying opportunities still exist. The registered foreign retirement plan is an ideal asset protection vehicle for Chinese investors that make investments that […]

IRC 402b Foreign Retirement Plans

11 Apr
402b

There are 4 sections of IRS code that need to be considered in regards to non-qualified deferred compensation plans and a U.S. tax lawyer who is without prior research on IRC 402b foreign retirement plans will bill between $125,000.00 and $200,000.00 prior to doing research on foreign country pension laws. The reason that specialist Tax […]