Family Wealth Management In Luxembourg: We Are Not Done Yet, Despite The Changes To The Information Exchange

With the announced end of banking secrecy for non-residents, the time has come to make use of favourable repatriation schemes, such as the voluntary disclosure regime in Italy. Despite increasing pressure for fiscal transparency and exchange of information, beneficial owners still have a choice: move the capital out (of Luxembourg), or move the owner in.
EXCHANGE OF INFORMATION – A GLOBAL STANDARD AND A LUXEMBOURG REALITY
Over the last few years, the financial landscape in Luxembourg […]

By |October 24th, 2014|

United States: Tax Victory For Collectors: Discounted Art Interests Turned $9 Million Tax Bill Into $14.3 Million

Last month, the United States Court of Appeals for the Fifth Circuit issued a decision granting a multimillion dollar estate tax refund to the Estate of James A. Elkins, Jr., a prominent Houston businessman, philanthropist and art collector. The reason? The Elkins family had employed a tax-planning technique whereby each family member (including Mr. Elkins) owned a fractional interest in the family’s art collection. The Fifth Circuit held that the Estate was entitled to […]

By |October 24th, 2014|

United States: New York State Tax Appeals Tribunal Finds Substantial Intercorporate Transactions, Allows Corporation Franchise Tax Combined Filing

In a precedential decision, the New York State Tax Appeals Tribunal has determined that a group of taxpayers was allowed to file a combined New York corporation franchise tax return because it met the substantial intercorporate transactions test for combination.1 The Tribunal also acknowledged that combined reports may be permitted based on a showing that separate reporting results in distortion, even in the absence of substantial intercorporate transactions. The ruling overturned an Administrative Law […]

By |October 23rd, 2014|