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Friday, 05 December 2025 08:40

Lifetime Gifts and Testamentary Transfers by US Grantors to Non-Citizens

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

US Estate and Gift Tax on US Citizens and Domiciliaries

The US estate and gift tax is imposed on lifetime gifts and the “gross estate” of US citizens and domiciliaries (residents who intend to stay in the US indefinitely).[1]

Published in Publications

Wednesday, 03 September 2025 16:20

SCOTUS Brightens Constitutional Tax Lines Through Contrasting Judicial Perspectives

Article Written for: Florida Bar Journal

The U.S. Supreme Court ruled on three significant federal tax cases last year. The rulings significantly impact tax policy and illustrate the contrasting perspectives of the justices.

Published in Publications

Monday, 21 April 2025 13:22

SCOTUS Brightens Constitutional Lines on Regulatory Authority

Article Written for: Florida CPA Today Magazine, FICPA Florida Institute of Certified Public Accountants

The Supreme Court of the United States (SCOTUS) ruled on three significant cases in 2024, all of which, though unrelated in substance, will significantly impact future tax policy.

Published in Publications

Tuesday, 07 January 2025 09:21

SCOTUS Exposes All Regulations to Court Scrutiny in Loper Bright

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

In Loper Bright Enterprises et al. v. Raimundo, 544 F. Supp. 3d 82, 103-04 (2021), the U.S. Supreme Court overturned the Chevron doctrine, a policy of deferring court discretion to federal agency regulations. Chief Justice Roberts authored the majority (6-3) opinion.

Published in Publications

Monday, 09 December 2024 11:55

SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

In Moore v. U.S. (36 F. 4th 930), the U.S. Supreme Court ruled on a constitutional challenge of IRC section 965, the mandatory repatriation tax (MRT).

Published in Publications

Friday, 04 October 2024 11:47

Pre-Immigration Planning and the Foreign Trust

Article Written for: Florida CPA Today Magazine, FICPA Florida Institute of Certified Public Accountants

For U.S. income tax purposes, foreign trusts are treated as non-resident/non-citizens (NRNC), subject to U.S. income tax only on U.S. source income.^[1]

Published in Publications

Monday, 04 March 2024 19:00

Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax

Article Written for: Florida Bar Journal

A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to U.S. income tax only on U.S. source income.^[1]

Published in Publications

Monday, 13 November 2023 08:46

Foreign Trusts: Income Tax and the Nonresident Noncitizen Grantor

Article Written for: the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants

Foreign trusts generally incur taxable income similar to nonresident noncitizen (NRNC) individuals, with certain limitations on credits and deductions that are source income.¹

Published in Publications

Tuesday, 22 August 2023 20:00

Foreign Trusts: Income Tax and the U.S. Grantor

Article Written for: the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants

A foreign trust is generally treated as a nonresident noncitizen (NRNC) holding for U.S. income tax purposes. Therefore, foreign trusts are subject to U.S. income tax only on U.S. source income.[1]

Published in Publications

Thursday, 08 June 2023 12:41

The Inheritance Tax under IRC §2801

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

The Heart Act added a new federal Inheritance Tax on certain lifetime and testamentary dispositions to U.S. recipients, made by a “covered expatriate.” This is the second article in our two-part series on the expatriation tax.

Published in Publications

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Our mission is to serve as a resource for complex domestic and international business transactions, tax, health law, asset protection, and related litigation.

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Gary presents his seminar, "Modern Asset Protection and Tax Strategies for the Nevada CPA: Including Key Insights from the One Big Beautiful Bill Act and U.S. Supreme Court Rulings," for the NVCPA at RubinBrown in Las Vegas, NV

10 December 2025

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from 8:30 AM to 5:30 PM

Lifetime Gifts and Testamentary Transfers by US Grantors to Non-Citizens

SCOTUS Brightens Constitutional Tax Lines Through Contrasting Judicial Perspectives

SCOTUS Brightens Constitutional Lines on Regulatory Authority

SCOTUS Exposes All Regulations to Court Scrutiny in Loper Bright

SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

Pre-Immigration Planning and the Foreign Trust

Pre-Immigration Planning with the Foreign Trust: The Intersection of Income and Estate Tax

Foreign Trusts: Income Tax and the Nonresident Noncitizen Grantor

Foreign Trusts: Income Tax and the U.S. Grantor

The Inheritance Tax under IRC §2801

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