Consequences of Modification of a QTIP Trust Settlement

By dakins | October 23, 2014

Consequences of Modification of a QTIP Trust Settlement: One Scenario in ‘The Tale of Moné Baggs Smith’ A “QTIP” trust is a “Qualified Terminable Interest Property” trust. It is often used by spouses in a second or subsequent marriage where at least one party has children from a previous marriage. The QTIP trust allows the…

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Swiss Adopt Banking Protocol Allowing U.S. to Request Information

By dakins | March 30, 2012

On March 5, the Swiss parliament adopted an amended ratification of the 2009 Protocol to the Swiss-US Income Tax Treaty. The protocol was signed by United States and Swiss tax officials on September 23, 2009 to allow a greater tax information exchange between the countries in the aftermath of the UBS tax evasion controversy and…

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New Offshore Voluntary Disclosure Program for 2012

By dakins | January 10, 2012

Yesterday, the IRS started the Offshore Voluntary Disclosure Program (2012 OVDP), which is a modified continuation of the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI).  The IRS will also release a new FAQ and provide additional details of 2012 OVDP on its website in the coming months. 2012 OVDP comes on the heels of last…

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Hill v. Davis: Challenging Qualifications of the Personal Representative

By dakins | September 14, 2011

It’s rare that probate procedural issues make their way to the Supreme Court of Florida.  However, on September 1, 2011 the Court issued its highly anticipated decision in Hill v. Davis, 36 Fla. L. Weekly S487 (Fla. 2011).  The issue at hand is whether §733.212(3) of the Florida Statutes (2007) bars a challenge to the…

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IRS Extends Offshore Reporting Deadline

By dakins | August 29, 2011

Due to Hurricane Irene, the IRS extended the deadline for participating in the Offshore Voluntary Disclosure Initiative (OVDI) from August 31, 2011 to September 9, 2011.  The new deadline applies both to submissions into the program and requests for a 90 day extension. For details on the OVDI program, please see our previous posts located…

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Offshore Voluntary Disclosure Initiative

By dakins | June 27, 2011

On April 11, we summarized the 2011 Offshore Voluntary Disclosure Initiative (OVDI). Last week, the Internal Revenue Service updated its online FAQ, which provided several changes or expansions to the program. First, in limited situations, the IRS will consider up to a 90-day extension to enter the program upon a taxpayer’s request and a good…

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The IRS Offshore Voluntary Disclosure Initiative

By dakins | April 11, 2011

In February, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI). The purpose of OVDI is to bring taxpayers that used undisclosed foreign assets to avoid tax into compliance with U.S. tax laws. OVDI, which is similar to the 2009 Offshore Voluntary Disclosure Program, ends on August 31, 2011.   OVDI provides taxpayers with…

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