U.S. citizenship is a privilege for many, but it can also be a burdensome and unwanted obligation for others. Some individuals find themselves to be U.S. citizens without wanting to be, such as if their parents...more
In a May post, I observed: As a long-time beneficiary of corporations fleeing other jurisdictions, Delaware may be tempted to put the brakes on its own corporations wishing to flee to the sunny uplands of other states. ...more
Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more
Ever thought about packing it all up and starting that romantic, expatriate life abroad? Ever felt like these parts were just so wild, it was time to find yourself a new passport? Expatriation, where a US citizen renounces...more
The UK tax legislation imposes an “exit tax charge” on the unrealised capital gains of a company which migrates from the UK. The exit of a taxpayer (or their assets) is generally the last point in which a taxing jurisdiction...more
Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more
Everyone has heard about the affluent, or even not-so-affluent, New Yorkers who have moved to Florida, or to another state, to escape New York’s tax regime, not to mention the cold. More recently, some of us are...more
Goodbye New York- Late last year, the U.S. Census Bureau released data showing population shifts across the country during 2021. According to this information, New York lost 1.8 percent of its population... ...more
Ever since the advent of FATCA and related global tax transparency movements, U.S. individuals living abroad have likely become far too acquainted with the challenges posed by holding U.S. citizenship or residency. Perhaps...more
There are many good reasons to move abroad, such as retirement or to begin a new career. But before finalizing plans, a thorough review of financial and estate plans is in order. This article answers key estate planning...more
Departing Individuals- Many of you may know that an individual who changes his status from New York (“NY”) resident to nonresident is required to accrue to the period of his NY residence – i.e., include in his final NY tax...more
The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more
Background - The Commission has published a proposal for a Council Directive, the ‘Anti Tax Avoidance Directive’ (the “Proposed Directive”), confirming the Commission’s intention to combat tax avoidance and to coordinate...more
The proposed Council Directive marks another, significant, though likely problematic, step towards tackling tax avoidance across Member States. Background - The European Commission (the Commission) has been moving...more
Our Focus on Private Equity provides a global perspective on some of the challenges being faced by PE firms and how these can be successfully addressed. It also examines some of the many opportunities available, e.g., by...more
The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more