S Corporations With Foreign Owners

The 2017 Tax Cuts and Jobs Act changed the rules dramatically with respect to S corporations in one particular: non-citizen non-resident shareholders. Before the change,

Teach Children Financial Responsibility

As the year draws closer to an end, many parents will consider making gifts to their adult children.  Part of that gift giving conversation should

Tax Court Highlights the Folly of Indirect Gifts

There was a time, and there may well be one again (see Bernie’s plan), when each person did not have an $11.4 million (in 2019)

An International View of Faulty ILITs

When international estate tax rules are layered onto common errors in Irrevocable Life Insurance Trusts (“ILITs”), the consequences can be dire.  PLR201941008 illustrates one common

Estate Plans That Stick

An estate plan is a snap shot. It takes into account the facts and circumstances that one knows or anticipates at a particular moment in

5 Mistakes Canadians Make in America

Failure to count days. Canadians who spend time in the United States, absent an exception, must be mindful that the number of days they spend

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