Search Results for: Trusts and Estates

Articles


IRS Grants Certain Deductions for Estates and Non-Grantor Trusts, Including Excess Deductions on Termination by Jeffrey M. Mutnik, CPA/PFS

The Internal Revenue Service (IRS) recently issued final regulations that allow decedents’ estates and non-grantor trusts to claim certain deductions that would otherwise have been disallowed under the 2017 overhaul of the tax code. The Tax Cuts and Jobs Act (TCJA) barred individuals, estates and non-grantor trusts from claiming miscellaneous itemized deductions for any taxable […]

Hurricane Helene Victims Receive Relief for Filing Annual Reports of Foreign Bank and Financial Accounts (FBAR) by Arthur J. Dichter, JD, LLM, TEP

The Financial Crimes Enforcement Network (FinCEN) today postponed the 2023 Report of Foreign Bank and Financial Accounts (FBAR) filing deadline from Oct. 15, 2024, to May 1, 2025, for taxpayers who live in federally designated disaster areas in the wake of Hurricane Helene. This six-and-a-half-month filing extension applies to qualifying taxpayers in Alabama, Georgia, North […]

UPDATED – IRS Delays Various Tax Deadlines for Victims of Hurricane Helene and Hurricane Milton by Angie Adames, CPA

The IRS today is providing tax relief for individuals and businesses affected by Hurricane Helene and Hurricane Milton by extending various tax-filing and tax-payment deadlines to May 1, 2025. The delayed deadline applies automatically to taxpayers with homes or businesses in jurisdictions declared federal disasters by the Federal Emergency Management Agency (FEMA), which includes the […]

Recent Court Rulings Uphold Congressional Authority to Assess Taxes and Penalties on U.S. Taxpayers with Foreign Interests by Andrew Leonard, CPA

The IRS scored significant wins in two separate cases before the U.S. Supreme Court and D.C. Court of Appeals. While both matters addressed different provisions of the tax code, the court’s decisions essentially fortified the IRS’s international reach and its ability to enforce compliance with various U.S. tax laws regarding taxpayers’ foreign investments and business […]

IRS Extends Tax Relief to Victims of Hurricane Debbie in South Carolina, Vermont and Portions of Florida and Georgia by Steven Rubin, CPA

The IRS has extended until Feb. 3, 2025, various tax-filing and tax-payment deadlines for individuals and businesses recently impacted by Hurricane Debbie, which first made landfall on Florida’s Gulf Coast in early August. The postponed deadline applies automatically to taxpayers with homes or businesses located in the following jurisdictions declared as federal disaster areas: Florida: […]

IRS Updates Guidance Related to Foreign Gains and Losses Under Section 987 by Jairan Shirazi

One of the more challenging tax reporting requirements for multinational businesses is the translation of gains and losses of their foreign branch offices and qualified business units (QBUs) into their home country’s functional currency. This process is often complicated by exchange rate fluctuations, including currency devaluations, that can have a material impact on the principal […]

Stricter Reporting Requirements Create Planning Opportunities for Foreign Trusts by Joel G. Young, JD, LLM

In May 2024, the IRS issued proposed regulations concerning the reporting requirements and tax consequences of U.S. persons who create, fund, transact with and receive gifts or loans from foreign trusts. The guidance, which applies to Sections 643(i), 679, 6039F, 6048, and 6677 (the foreign trust and gift provisions) of the U.S. tax code, updates […]

U.S. Taxpayers Living Abroad May Have Opportunities to Claim Tax Refunds for Foreign Tax Credits Applied Against Net Investment Income Tax by Andrew Leonard, CPA

A recent decision by the U.S. Court of Federal Claims may open the door to a potential deluge of requests for tax refunds from U.S. citizens and resident aliens living or working in foreign countries with which the U.S. has an income tax treaty. In Christensen v. United States, the court interpreted the U.S.-France Income […]

IRS Resumes Automatic Collection Notices, Provides Failure-to-Pay Penalty and Accrued Interest Relief to Some by Angie Adames, CPA

The IRS announced it is resuming mailing automated collections and reminder notices to taxpayers with outstanding tax liabilities from 2021 and earlier, a practice it suspended in 2022. In certain circumstances, the agency will waive failure-to-pay penalties that accrued in tax years 2020 and 2021 during the height of the COVID pandemic. It is estimated […]

How to Protect Art Collections from Gift and Estate Tax Exposure by Lewis Kevelson, CPA

According to a recent study by Art Basel and UBS, global art sales in 2022 exceeded pre-pandemic levels, reaching $67.8 billion in transactions. Buyers, ranging from high-end collectors to Gen Xers and Millennials, increasingly recognize art’s value as an alternative investment in a fragile economic and geopolitical environment. However, as buyers grow their collections, they […]

Understanding Foreign Trusts and Their Tax Treatment in the U.S. by Pedro L. Porras, CPA

In a global society where business and family affairs are conducted regularly across international borders, it is very easy for individuals’ activities to fall unintentionally under the taxing authority of another country. This is especially true when it comes to foreign persons making gifts and passing inheritances to heirs located in the U.S. With a […]

Owning and Selling C Corporations vs. S Corporations by David E. Kolan, CPA

The pandemic has spurred a tsunami of entrepreneurial new businesses. According to the U.S. Census Bureau, a record 5.4 million new business applications were filed in 2021, compared to 4.4. million in 2020 compared to 3.5 million before the pandemic in 2019. Whether these ventures will prove successful remains to be seen, but each one […]

Trusts Are Running Out of Time to Reduce 2021 Tax Liabilities by Rick Bazzani, CPA

Under the IRS’s 65-day rule, estates and certain complex trusts still have some time to reduce their income-tax liabilities for 2021, but immediate action is required. Calendar year-end trusts have until Sunday, March 6, to distribute trust income to beneficiaries and treat those payments as if they occurred in 2021. Doing so not only reduces […]

Will Grantor Trusts Become Extinct? by Jeffrey M. Mutnik, CPA/PFS

If and when Congress passes a law reforming the tax code, there is a general expectation that taxes will increase, and some commonly used estate planning strategies will be added to the endangered species list. Among the tools being targeted are irrevocable grantor trusts, which have long enabled grantors to remove appreciating assets from their […]

UPDATED – Preparing for Potential Changes to Individual and Estate Taxes by Tony Gutierrez, CPA

As the government begins deliberating the Biden administration’s $2.3 trillion infrastructure bill and $1.8 trillion American Families Plan, one thing is for certain: individual and corporate taxes will be impacted. Now is a critical time for high-net-worth families and businesses to get ahead of proposed tax increases and meet with their CPAs and advisors to […]

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International Tax Planning and Compliance

Our firm’s international tax practitioners are widely recognized as thoughtful advisors and strategic thinkers who structure transactions to minimize cross-border taxation.

International Tax Services

Our firm’s international tax practitioners are widely recognized as thoughtful advisors, strategic thinkers and valuable business partners. Many of our multi-national clients have worked with us for many years as their companies have grown and evolved. Tax Planning and Compliance Assessing the tax impact of currency fluctuations Branch terminations Federal, state and local tax compliance […]

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Guillermo Campos, CPA

Guillermo Campos has nearly 25 years of experience handling international and domestic tax matters for clients. He specializes in helping high-net-worth individuals, trusts and estates, closely held family companies, including corporations and partnerships with their pre-immigration tax planning issues. Campos advises foreign and domestic high-net-worth families on U.S. income, gift and estate tax matters, cross-border […]

Sarah Gaymon, CPA

Sarah Gaymon helps high-net-worth individuals create sophisticated trust and estate structures that enable them to plan for wealth transfer and advantageous tax status. Multi-generational families benefit from her depth of knowledge and skill. With more than 10 years of experience, Gaymon also handles trust accounting services, foreign trusts and year-round tax planning. Her clients represent […]

Arthur J. Dichter, JD, LLM, TEP

Art Dichter has more than 30 years of experience assisting international private clients with planning and compliance for foreign trusts, cross-border estates, pre-immigration strategies, investments in US real estate and US tax compliance matters.  He is the leader of BPB’s International Tax Services Group, one of South Florida’s largest international tax teams with more than […]

Rick Bazzani, CPA

Rick Bazzani specializes in the taxation of estates, trusts, gifts and individuals. He is experienced in estate tax planning, individual tax planning and representation before governmental agencies in connection with tax audits. Bazzani has diversified experience consulting with personal representatives, trustees, beneficiaries and professional service providers regarding tax, administrative and probate issues.

Press Releases


Berkowitz Pollack Brant Promotes Guillermo Campos, CPA, to International Tax Director

MIAMI, February 27, 2020 – Berkowitz Pollack Brant Advisors + CPAs has promoted Guillermo Campos, CPA, to director. Multi-lingual in English, Spanish, Portuguese and Italian, he focuses on international and domestic tax matters for high-net-worth individuals and families, trusts and estates, and closely held family companies. “We are proud to recognize Guillermo’s achievements,” said Joseph […]

Berkowitz Pollack Brant Promotes 9 to Associate Director

July 13, 2023 – Berkowitz Pollack Brant Advisors + CPAs today announced the promotion of nine professionals to associate directors within the firm’s Tax Services and Assurance and Advisory Services practices. “Our firm was founded on the principle of creating a life-long learning environment, where every firm member receives the tools to cultivate knowledge, enhance […]

Arthur Dichter Appointed to Private Client Global Elite Directory

MIAMI, FL., – October 11, 2021 – American Lawyer Media appointed Berkowitz Pollack Brant Advisors + CPAs Director of International Tax Services Arthur Dichter, JD, LLM, to its Private Client Global Elite Directory. Private Client Global Elite is a global directory of the world’s elite lawyers advising ultra-high-net-worth clients. The directory is made up of […]