POWERS OF ATTORNEY AND ALTER EGO TRUSTS

Tuesday, September 16th, 2014

My fellow bloggers and I have written in the past about the ins and outs of legitimate probate fee avoidance arrangements available to a testator. These arrangements include an intervivos transfer of assets such as alter-ego trusts. Care and advice must be taken to ensure that the transfer of assets ...

PRICE ADJUSTMENT CLAUSES IN ESTATE PLAN AGREEMENTS

Thursday, August 28th, 2014

Many estate plans include a transfer of property (e.g. shares of a privately held corporation) to a company and freeze the value (or price) of the transferred property to the current owners at the transfer date. To avoid some punitive provisions in the Income Tax Act associated with non-arm’s ...

US TAX FILING OBLIGATIONS FOR NON-RESIDENT US CITIZENS: SOME IRS RELIEF!

Tuesday, August 12th, 2014

Under most circumstances, citizens of the United States must file annual income tax returns regardless of residency. In 2012, the Internal Revenue Service (“IRS”) introduced 2 voluntary compliance programs to allow US citizens to comply with their income tax filing obligations thereby avoiding possible criminal prosecution and penalties: 1. the ...