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Tax Implications of Exiting a Domestic C Corporation
News and Insights

Tax Implications of Exiting a Domestic C Corporation

Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best security, most privacy, best income, lowest taxes, and lowest costs. While the extremely wealthy often utilize these trust structures, they are in no way limited to the extremely wealthy and are often used by high-net-worth individuals (i.e., more than a million in assets). For many, it is also important to diversify their asset holdings outside their country of residence. Powerful trust laws, tax savings, asset protection and privacy, as well as solutions to political and regulatory concerns, all combine to make the U.S. the trust situs of choice.

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Christopher Klug May 9, 2023
Why Are the Global Elite Using U.S. Trusts?
News and Insights

Why Are the Global Elite Using U.S. Trusts? (It’s not to get their head on Mt. Rushmore)

Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best security, most privacy, best income, lowest taxes, and lowest costs. While the extremely wealthy often utilize these trust structures, they are in no way limited to the extremely wealthy and are often used by high-net-worth individuals (i.e., more than a million in assets). For many, it is also important to diversify their asset holdings outside their country of residence. Powerful trust laws, tax savings, asset protection and privacy, as well as solutions to political and regulatory concerns, all combine to make the U.S. the trust situs of choice.

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Christopher Klug April 25, 2023
Qualified Small Business Stock
News and Insights

Getting the Tax on Qualified Small Business Stock Correct

With the reduction of the corporate income tax rate from 35 percent to 21 percent and the ability to exclude a significant amount of gain on the sale of Qualified Small Business Stock (“QSBS”), many startups choose to organize as C corporations.  Many practitioners believe that gain recognized above the excludible amount is not eligible for regular long-term capital gains and is taxed at a 28 percent tax rate.  This is simply not the case and this misinterpretation has cost founders and other investors significant amounts in additional tax.  It is important that the tax advisor has a thorough understanding of the QSBS rules including the applicable tax rates for certain gain recognized on the sale of QSBS stock. 

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Christopher Klug April 11, 2023
Clowns of the CRUT Part 2 of 2
News and Insights

Clowns of the CRUT (Part 2 of 2)

This is Part 2 of the newsletter on charitable remainder unitrusts (“CRUT”) which is a common planning technique for the charitably inclined high net worth family. As compared to immediate taxation on the gain on the sale of a highly appreciated asset with after tax proceeds being subject to tax annually, the CRUT can allow for superior returns where the distributions to the lifetime beneficiaries will…

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Christopher Klug April 3, 2023
Clowns of the CRUT (Charitable Remainder UniTrust) 1
News and Insights

Clowns of the CRUT (Part 1 of 2)

A charitable remainder unitrust (“CRUT”) is a common planning technique for the charitably inclined high net worth. The CRUT allows for the tax-free liquidation of a highly appreciated asset, the tax-free growth of the assets inside the CRUT, with the income building inside the CRUT being taxed to the extent of distributions to the lifetime beneficiary. As compared to immediate taxation on the gain on the …

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Christopher Klug March 27, 2023
News and Insights

Tax Planning for Foreign Investors

With the global economy we live in, it is important for Fund Managers to have an appropriately structured fund if they plan to have foreign investors.  Too often, the fund structure is not tax efficient for the foreign investor.  If the fund is not structured to accommodate foreign investment, why should a foreign investor consider investing in the fund?

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Christopher Klug March 7, 2023
News and Insights

Comprehensive Planning to Provide the Most Tax-Efficient Structure

CFOs and General Counsel of multinational corporations (non-U.S. parent) with operations in the United States face complex tax implications that must be planned for on a global basis and not make decisions solely based on the U.S. tax implications. Too often, the U.S. advisor will ignore the tax …

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Christopher Klug March 1, 2023
Membership Interest for Services and Purchaser’s Tax Liability
News and Insights

Membership Interest for Services and Purchaser’s Tax Liability

The after-tax proceeds of the sale of a business is of the utmost importance to sellers. Too often sellers agree to holdbacks or a reduction in purchase price for alleged tax issues raised by the purchaser during due diligence where the purchaser bears no actual risk.

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Christopher Klug February 15, 2023
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