Trust Planning for Private Equity Executives
Trust and Inheritance Planning for Private Equity Executives Trust planning for private equity executives works best when carried interest and fund equity are removed from the estate early, before they appreciate. Freezing today’s low value inside a trust can shelter tens of millions from US estate tax and UK inheritance tax across the Atlantic. By […]
Form 8938 Reporting: What Wealthy US-UK Clients Should Know
Form 8938 Reporting: What Wealthy US-UK Clients Should Know For wealthy Americans in Britain, Form 8938 reporting is the annual disclosure of your specified foreign financial assets to the IRS, filed with your 1040. Miss it, and you risk a $10,000 penalty, a 40% understatement charge, and a tax year that never closes. By the […]
Trust Planning for Elite Athletes Abroad
Trust and Inheritance Planning for Elite Athletes Abroad Effective trust planning for elite athletes abroad protects compressed career earnings, provides injury-linked liquidity, and shields image-rights income across two tax systems at once. Started early, before a US move or a UK signing, it shields wealth from a 40% estate tax on one side and residence-based […]
Unfiled US Returns C-Suite Expats: The Catch-Up Guide
How C-Suite Expats Catch Up on Years of Unfiled US Tax Returns The fix for unfiled US returns c-suite expats owe usually runs three years of amended returns plus six years of FBARs through the IRS Streamlined Foreign Offshore Procedures. Certify the failure was non-wilful, and the standard 0% penalty track wipes out the fines […]
 PFIC Planning Senior Law Firm Partners
Investments to Escape the PFIC Trap PFIC planning senior law firm partners turn one quiet problem into a workable strategy: US persons who make equity partner at a UK or global firm hold large portfolios that are silently taxed as passive foreign investment companies. Escaping the trap means choosing US-domiciled funds, direct holdings, and treaty-protected […]
Streamlined Eligibility Entertainers With Global Income
Are Entertainers With Global Income Eligible for the Streamlined Foreign Offshore Procedures? Yes. Streamlined eligibility for entertainers with global income hinges on two tests: certifying non-wilful conduct on Form 14653 and passing the non-residency test. Touring artists who lived outside the United States for 330 or more full days in one of the last three […]