November 2015

Willfulness

So much of the discussion around the IRS amnesty initiatives lies in the concept of “Willfulness”. While nothing here should be construed as legal advice, here are some key points to consider – 31 U.S.C. § 5321 (a)(5)(C)imposes upon any person who “willfully violat[es]” or “willfully caus[es] any violation of … section 5314,” a penalty

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Nonresident Aliens Can Be Subject to the U.S. Estate Tax – But Usually Ignore It

Here’s an article from CNBC’s website dated Nov 4th 2015 –  Aleksandar Stojanov | Getty Images They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign

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Structuring using St Vincent entities

Among the up and coming offshore jurisdictions is St. Vincent and the Grenadines (SVG). At this point in time, the SVG IBC is not required to make public filings or disclosures of its directors, shareholders/members or beneficial owners. The SVG IBC is useful for asset protection, tax planning, or succession planning. SVG also offers international

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