With a mixture of fondness and heavy hearts, we recently sad goodbye to Peggy Ugent, who retired in April after nearly 12 years with the firm. As GSRJ’s Director of Tax and Accounting, Peggy used her extensive expertise and background in U.S tax matters to counsel firm attorneys on income and transfer tax considerations with regard to proposed business transactions, choice of entity structure, and investment in pass-through entities. She has not disappeared from the industry completely, though; as the current chair of the American Institute of Certified Public Accountants’ Trust, Estate and Gift Tax Technical Resource Panel, she continues to share her deep knowledge of complex domestic and international tax issues.
On Saturday, February 24th, COO and Finance Director Bob Chesner once again presented at Tony Robbins’ Platinum Partnership event, held this year in Sun Valley, Idaho. Bob’s presentation highlighted the power of private placement life insurance in creating abundant tax-free retirement income. We’re thrilled that Bob was once again extended the incredible opportunity to share his passion among such distinguished company.
For the first time ever, GSRJ associate Lauren Fitte has been selected for inclusion in the 2018 Texas Super Lawyers Rising Stars list! Lauren has been with GSRJ since early 2017. She specializes in designing tax-efficient structures for U.S. and non-U.S. families and advises with regard to both inbound and outbound investment planning, inheritance planning, asset protection, tax compliance matters, international trust and estate planning, and pre-immigration planning. Ms. Fitte is a certified mediator who has published several articles on international estate planning and taxation. She is also a contributing editor to the four-volume treatise Asset Protection: Domestic and International Law and Tactics, published by Thomson/West group and updated quarterly.
Super Lawyers is a rating service of outstanding lawyers from more than 70 practice areas who have attained a high degree of peer recognition and professional achievement. The selection process includes independent research, peer nominations and peer evaluations. No more than 2.5% of up-and-coming lawyers in Texas are named to Rising Stars, as determined by Thomson Reuters.
In the wake of Sandra Bonham’s retirement earlier this year, Hailey Bobella has taken over as the paralegal for the estate planning department. She works primarily with Derry Swanger and Steven Baker to help clients create and maintain domestic estate planning structures and administer decedents’ estates. Ms. Bobella will also continue to act in her capacity as business development specialist, focusing on the firm’s business development, marketing, and branding efforts, and offering administrative support to Edgewater Consulting Group, Ltd.
In the two weeks since President Donald Trump issued his executive order restricting travel to the United States, our country has been confronted with many challenging questions. Countless legal minds have wondered, “Is this politics as usual or something altogether different?” There are no easy answers. In the legal and constitutional chaos that have resulted, however, firm partner Cindy Grossman has found an edifying opportunity to affirm her identity and pride as a lawyer. We asked her a few questions about her pro bono assistance at Newark Liberty International Airport, and what it all means to her.
GSRJ: How did you first get involved?
CLG: My experience with what is now (mostly humorously) known as the Law Firm of the Resistance started the Sunday morning after the order was signed. Despite my lack of direct experience in immigration law, I can research and write, and with some guidance, I can understand enough of a new area of law to be helpful to the experts. So, after perusing the Facebook page of “Lawyers for Good Government” and seeing the massive network of like-minded individuals who sprang up overnight to defend our Constitution, I decided I would sign up to volunteer. I’m so glad I did.
GSRJ: What has the experience been like?
CLG: Well, things have been a little quieter at Newark than at some of the larger airports throughout the country. We haven’t necessarily been dramatically running to the courthouse to file habeas corpus petitions. Instead, we mostly stay abreast of any developments with the various legal challenges across the country and others’ practical experiences with Customs and Border Protection, and then monitor incoming flights for affected travelers to help prepare them for what they may experience when passing through immigration, and to offer any advice that we can. Many of those travelers are simply comforted to know that we are tracking their arrival, and that we’re right on the other side of immigration should they need us.
A broader part of the work has been through email and Twitter. Lawyers of all stripes, throughout the country, have been using the internet to stay in touch, to offer expertise in drafting documents, to deal with law enforcement groups, and to provide each other with words of encouragement. Essentially, thousands of lawyers throughout the nation coalesced seemingly out of nowhere to do what they do best: turn a chaotic situation into an orderly one.
GSRJ: How has it impacted you personally?
CLG: I have never been so proud to be a lawyer. To see so many selflessly offer all that they know, as well as their time, in the name of advocacy for those who do not have a voice has been a humbling and inspiring experience. It’s been an educational one, too; after watching a group of at-the-ready-lawyers join forces band together to uphold their view of the Constitution, our laws, and our government, I recalled the point Shakespeare was making when he had Dick the Butcher proclaim “The first thing we do, let’s kill all the lawyers” in Henry IV! We can truly be a force to be reckoned with.
On a more personal note, too, the incredible diversity of those battling on the front lines alongside me made an impression. Sitting at our makeshift clinic table by Green Beans Coffee in Terminal B, I was struck by the cross-section of America that I shared the table with. Of our two Arabic interpreters, one was a first generation American whose parents came to this country from Qatar. The other was a young white man from an elite northeastern college. Our attorneys included a married couple, Punjabi by ancestry, who had grown up in Iraq and still have parents living there, a Latina immigration lawyer who worked in Biglaw, and a woman who had dusted off her law degree to come out of retirement and help. We also had a female Egyptian lawyer who works with refugees, a young female lawyer who works in the Newark public defender’s office, and me – a Jewish tax lawyer recently transplanted from Austin, Texas.
It is necessary to have all those voices at the table to formulate our responses. As cliché as it might sound, our diversity truly is our strength. I will absolutely cherish this experience; it has been exciting and consistently impressive to witness so many attorneys roused from their corporate slumber to answer the primal call of our profession and defend our system of laws. I hope that many of us will continue this hard, important work as we return to our normal practices, and take to heart the lesson of our role in American society. I know that I will.
On August 4, 2016, the United States Treasury Department issued proposed regulations to Section 2704 of the Internal Revenue Code. These new regulations, if put into effect as currently written, will significantly impact the ability of taxpayers and their advisors to utilize previously available valuation discounts when determining the value of interests in family-owned limited partnerships, limited liability companies, and corporations for gift, estate, and generation-skipping transfer tax purposes. That is to say, some strategies that estate planners use to decrease the burden of gift taxes for lifetime transfers and estate taxes after a taxpayer’s death may no longer be viable if the proposed regulations become final.
There will be a brief period of time before these new regulations become final during which clients can take advantage of valuation discounts for commonly used estate planning strategies. Gifting plans, if desired, should be enacted with expediency, as they may no longer be valid after the regulations become final. By way of example: taxpayers who created family limited partnerships with the intention of transferring their interests at a later date will, after the passage of these regulations, potentially no longer be able to discount the value of the gift.
The proposed regulations could go into effect as early as the first quarter of 2017, after a scheduled public hearing on December 1. It is not yet known whether they will undergo changes before being officially enacted.
As always, a holistic and well-considered estate plan is crucial in planning for your family’s future. We invite you to reach out to your attorney for a better understanding of these new regulations, and to have a discussion about how your estate planning goals might be attained.
GSRP Partner Michael Ripp will present “Life Insurance and Annuities: Effective Tools in Pre-Immigration Tax Mitigation” at the 35th Annual International Tax Conference. Scheduled for January 5 and 6 in Miami, the conference is sponsored by the Tax Section of the Florida State Bar Association. The session will addresses the various applications of life insurance and annuity products for mitigating the federal tax consequences of immigrating to the U.S., whether temporarily or permanently. It will also emphasize the use of private placement contracts and other cost-efficient products of particular interest to the high net worth immigrant.
Michael’s primary expertise is advising non-U.S. individuals regarding the tax and legal issues involved in pre-immigration planning, temporary residency, and planning for gifts to their U.S.-resident families, both during lifetime and at death. A significant portion of his practice also involves advice regarding mechanisms for deploying leverage in the acquisition or monetization of assets, including real estate.
BNA Bloomberg published Tax Management Portfolio 870, Private Placement Life Insurance and Annuities, authored by GSRP’s Leslie Giordani and Bob Chesner, on September 2, 2013. Portfolio 870 explores all facets of PPLI and PPVA as financial products, and offers an in-depth examination of the uses of PPLI and PPVA, focusing on their importance as investment tools that have powerful applications in the areas of estate, income tax, and asset protection planning.
The world is shrinking. Overseas connections are expanding. Families are spread across countries and continents. Many people in the United States (and U.S. citizens living abroad) are beneficiaries of foreign trusts or estates, and even more seek to invest overseas.
These trends have not gone unnoticed. Congress, the Internal Revenue Service, and other governmental agencies are ramping up enforcement efforts and getting results. The IRS hired about 3,300 new agents and tax compliance officers in 2009-2010 alone!
The regulatory landscape has changed dramatically since passage of the Foreign Account Tax Compliance provisions of the HIRE Act of 2010 (“FATCA”). And in recent years, the IRS has offered two separate voluntary disclosure programs to U.S. persons who had failed to fully report foreign assets.
GSRP is a law firm with in-house senior accounting expertise and a robust offshore and domestic tax compliance practice. The boutique nature of our firm allows us to deliver highly-personalized services. Our clients in the U.S. and abroad are much more than just files. Our technical expertise and proven processes, which utilize the latest technology, enable us to provide services that are reasonably-priced and timely-delivered.