Matthew Rappaport

The Supreme Court, a court of original instance in New York State, determined that it had jurisdiction over a trust company that administered trusts in the Cook Islands and on the Caribbean island of Nevis, despite the trust company not... Read More

The New York Times recently published an article discussing Apple's corporate tax strategy, which makes use of international tax treaties and shrewd planning to make the company's effective tax rate about one-fourth of what it would have been wit... Read More

Roger Russell of Accounting Today explored the current state of the estate tax regime in the United States and found that professionals generally agreed on one idea: planning is very difficult when the law is changing with each passing year.... Read More

Kevin Packman and Jonathan Strouse of Holland & Knight warn that the IRS is being especially vigilant about the payment of a required foreign excise tax (FET) on certain foreign insurers and reinsurers of insurance policies either issued to America... Read More

The Wall Street Journal consulted Steve Weinstein of Altar Advisers about the state of the estate and gift tax exemptions, and he recommended that wealthy individuals and couples consider taking advantage of the current regulatory climate.  ... Read More

Daniel E. Martinez and Victor Perez of Holland & Knight LLP report that the IRS has put forth new regulations regarding the reporting of financial data to foreign countries in an effort to foster cooperation with those nations in... Read More

The Association for Advanced Life Underwriting (AALU) convened a panel of its legislative experts for its annual meeting, and the panel conveyed a consensus that Congress would reach a permanent figure for the estate tax exemption and rate schedule... Read More

BNA reports that practitioners are split over a quirk in the rules regarding the deceased spouse unused exclusion amount (DSUEA) found in I.R.C. § 2010(c)(2).  Under that provision of the Code, a deceased spouse's estate tax exclusion is "portabl... Read More

The IRS issued T.D. 9588, which promulgated final regulations and replaced temporary regulations regarding the allocation of qualified mortgage insurance premiums to find out how much of the pre-paid premiums are allowed to be classified as "Qualified... Read More

In PLR 201218015, an educational institution exempt under I.R.C. §501(a) served as Trustee of six Charitable Remainder Trusts whose corpus, or res, included "units" in the institution's endowment fund.  The "units" entitled the Trusts to profits ... Read More

Mark Zuckerberg and Dustin Moskovitz, two of the chief founders of Facebook, made an intelligent estate planning move in 2008 by setting up Grantor Retained Annuity Trusts (GRATs) for a large portion of their holdings in company stock.  A... Read More

Many financial industry representatives attended a hearing on May 15 to voice comments to the IRS about the implementation of the Foreign Account Tax Compliance Act, or FATCA.  Banks from abroad said that they would have difficulty conforming to... Read More

The Majority Staff of the Senate Budget Committee, which is entirely comprised of Democrats, went on the offensive as it released a short commentary regarding Senator Pat Toomey's (R-Pa.) budget proposal for the fiscal year 2013.  In it, the... Read More

Everyone in the wealth management, estate planning, and related industries is well aware that the tax rules associated with President Bush's cuts are set to expire at the end of the calendar year 2012.  Bill Bischoff of Smart Money provides... Read More

In 2011, the IRS issued Notice 2011-101, which was a request for comments about the tax treatment of trust "decanting."  "Decanting" is when a trustee transfers assets from one irrevocable trust to another irrevocable trust.  Mary McNulty of... Read More

Forbes analyzed the case of Dionne Warwick's tax lien to illustrate the idea that the IRS can, on rare occasion, be incorrect about the dollar amount of a tax lien.  Ms. Warwick was originally hit with a tax lien in... Read More

In the French Presidential election, Socialist candidate Francois Hollande was victorious over the incumbent, Nicolas Sarkozy, who was painted as the "rich man's candidate."  With Hollande supposedly planning to increase the top marginal tax rate... Read More

The U.S. Tax Court ruled that individuals who purchase a residence through a Subchapter S Corporation cannot claim the first-time home buyers' tax credit, considering the credit is reserved for "individuals" under §36(a).  The Trugmans purchased ... Read More

The U.S. Tax Court ruled that individuals who purchase a primary residence through an LLC cannot claim the first time home buyers' tax credit under §36(a).  This case was similar to the Trugman Case, wherein the taxpayers claimed the credit... Read More

The Congressional Research Service issued a publication analyzing the current U.S. economic situation and the concerns regarding the country's recovery from the recent financial crisis.  The CRS points out that there has been no period of above-a... Read More

According to Jesse Eggert, associate international tax counsel for the United States Treasury, the FATCA final regulations to be released later this year will almost assuredly not include any guidance regarding "pass-thru" payments.  "Pass-thru" ... Read More

... ליסינג פרטי - כידוע וכזכור, מגיל צעיר מלמדים אותנו שלא לשים את כול הביצים בסל אחד. בכל רגע, נתון אנחנו רוצים לחיות כמו בסרטים, והנה הזדמנות מצויינת להגשים את החלום- השכרת רכב בארץ. המטפל התקש... Ma... Read More

... חברות ליסינג - כידוע וכזכור, מגיל צעיר מלמדים אותנו שלא לשים את כול הביצים בסל אחד. בכל רגע, נתון אנחנו רוצים לחיות כמו בסרטים, והנה הזדמנות מצויינת להגשים את החלום- השכרת רכב בארץ. המטפל התקש... M... Read More