83(b) Elections: What You Need to Know

In certain circumstances, an employee may receive restricted stock as part of their compensation package. Restricted stock is a type of equity compensation in which the employee (perhaps a corporate…

The U.S. Exit Tax

Bye-Bye U.S., Hello Exit Tax! If you are a U.S. citizen thinking about relinquishing your U.S. citizenship, or if you are what is defined as a “long-term” green card holder…

Taxation of Trusts

How Trusts are Taxed We can talk hours about the intricacies of trust taxation, but here are some basic concepts that will still go a very long way when it…

Foreigners Owning U.S. Real Property

This is Part 3 in a three-part series about Estate Planning for Non-Citizens. In Part 1, I discussed general issues involving non-citizen planning. In Part 2, I discussed what is a…

Estate Planning for the Non-Citizen

This is Part 1 in a three-part series about Estate Planning for Non-Citizens. In Part 2, I discuss what is a QDOT. In Part 3, I discuss the various ways…

Qualified Small Business Stock & Use of Non-Grantor Trusts

This is Part 2 in a series I have written on the use of QSBS in estate planning. Part 1 focused on what is qualified small business stock. QSBS &…

Dynasty Trusts

This is a part in a series of articles I have written on various types of irrevocable trusts. What is a Dynasty Trust? Many people refer to dynasty trusts to mean…

SLATs and SLANTs

This is a part in a series of articles I have written on various types of irrevocable trusts. What is a SLAT? A SLAT stands for a Spousal Lifetime Access…

Sales to IDGTs

This is a part in a series of articles I have written on various types of irrevocable trusts. Intentionally Defective Grantor Trust What is a sale to an Intentionally Defective Grantor…

NINGs and California Residents

This is a part in a series of articles I have written on various types of irrevocable trusts. What is a NING? A Nevada Incomplete Gift Non-Grantor trust (NING) is an…