If I livestreamed my day, it would be a lot of me staring at a computer with a furrowed brow

Tax advice that is not delivered in privileged communications is very unwise. But, I see a large number of so called "fiduciary" advisers doing it to their clients

I've loved Arsenal FC since I was a kid watching them on Fox Sports Espanol! What a season (I think I've had about 50 heart attacks)!!!

Arsenal! Arsenal! Arsenal!!!

My advice to many graduating is to accept that the people we admire are virtually all polymaths. Get very good at many things that interest you. You do not have to be siloed

A child who moves to France or Germany can turn a normal US estate plan into a tax and compliance trap. Get advice from competent local counsel there and adjust as needed

One underdiscussed way to shield a noncitizen nonresident's US located estate from Estate Tax is to give it all to US charities (or zeroed out CLATs). If the client ultimately wants to fund charitable work abroad, this can still work through friends-of organizations or DAFs

Becoming a dual citizen, when you are a US citizen, does absolutely nothing to change your US tax status. Don't listen to the social media personalities selling you quick tax freedom by getting another passport!

QCDs are one of the few taxpayer friendly IRA distribution rules we have. Charitably inclined clients need to be using these to bolster their giving, particularly in light of the new 0.5% floor and 2/37 cap on itemized charitable deductions

The humble US nongrantor trust is the saf(ish) entry into US real estate that many more foreign investors need to consider You can protect against estate tax, fund gift tax free, take normal US deductions, eliminate double-tax, avoid FIRPTA, maintain anonymity

The reason AI is a terrible professional is because you don't know what to ask it and it doesn't "know" what to tell you. The great guessing machine is guessing up a storm out here though!

Don't just assume that because the condo in Mexico is owned in a fideicomiso (Mexican land trust) that the planning is done. You need to get a good attorney in Mexico to review the documents and help you plan for what happens in the future when an owner becomes incapacitated or dies

You can be a US estate tax resident and an income tax nonresident. That is a mind twisting, but true statement of our federal tax policy

If an American with a revocable trust moves abroad, you have to analyze, and potentially address, whether the principal place of the trust's administration has moved with them This could cause the trust to become a "foreign" grantor trust for US purposes, and a tax resident in the new jurisdiction

Foreign married couples purchasing joint tenancy property in the US is a landmine. If only one spouse pays, you may have a gift to the other spouse. When the contributing spouse dies, they own 100% of the property because Section 2056(d) negates the 50/50 rule in Section 2040(b)

Remember when everything was going to be an NFT and everything would be easy? Well, me too

This week on the podcast I release my full conversation with Darren Case about planning this year for the ultra high net worth. Enjoy!

An aggressive state income tax system without laws attempting to eliminate self-settled non-grantor trusts is just Swiss cheese tax policy (but not in the delicious way)

If birthright citizenship goes away--let's assume for a second that's possible--the tax fall out would be far reaching, harsh, and shocking for many people

Dear Washingtonians, may I introduce you to Wyoming?

Effective business succession discussions often begin with answering the following questions: 1. Who is going to be involved in, ownership, operation, or both? 2. Is the business "a business" or "THE business". What changes, if any, are permissible? 3. What structures and people can address 1 and 2?

You can pretty easily dismiss most of the click-bait stuff out there about how the "super rich" build wealth by not paying tax There is no monolith of the "super rich" to reference and often the promoters can't see beyond their own noses

Happy March 15 (16) to those who celebrate!

It's comforting when you call the IRS and they ask YOU to send THEM a copy of the already filed return. What a world we inhabit

Imagine an entire tax system built on fax technology...

The String Provisions say retained interests apply to transfers in trust "or otherwise." I see enough different structures to suggest many people forget about the "or otherwise" part

If/When those tariff refunds are paid, accountants are going to have fun adjusting COGS

This week on the Wealth and Law podcast, I chat with Brent Bowers about Strategic Investing in Land! Enjoy!

Getting over the hump to actually do the planning is the greatest inhibitor of planning. The human element is ever present.

To have a PFIC is like having a puppy who refuses to learn to be potty trained

I repeat.

If you create a Trump account, it doesn’t qualify for the annual exclusion because it isn’t a present interest and Congress didn’t create an exception (ala 2503(c), 2503(e), or 529 Plans). Instead you’ll be reporting that gift on a gift tax return. Another reason these are all sizzle and no steak.

I’ve seen enough naive and disjointed performances (Aston Villa, Wolves, United, Brentford) that my season long belief Arsenal will not win the league. They may well win a cup competition. But, they turn up far too often with a lack of control and incisiveness to convince me otherwise

Turns out, it is very difficult to win the Premier League. Who knew?

Wow!

I’m the world’s biggest Liverpool fan today

I like this change. Madueke was lively as usual but he gives up on challenges and doesn’t do enough to pin back the opposition when we lose possession, for he.

Raya has gone full Ramsdale here. Please make it stop

I’m having a lot of conversations with American citizens moving abroad. They are shocked to learn just how interested the US is in their financial lives abroad. Proceed with caution compatriots. Proceed with caution.

The Russian stiles never ceased, so how could they possibly be “renewed”? www.bbc.com/news/article...

Did Spurs forget they were playing City in a title race with Arsenal?

If your spouse died and you can’t make a portability election, you must be the spouse of a noncitizen nonresident

Eze with that freedom of movement is so beautiful to watch. He spent 15 minutes knitting together different combinations all over the pitch and then made an intelligent run that opened the space for Jesus to receive the pass that lead to his goal. More of that please.

See Arsenal, that’s how I prefer my weekends to go.

A real secret to learning the law is to write about the law. Writing is thinking and thinking is learning.

I’m so old now I still remember Cyber Ninjas 🌵

Tax efficiency isn’t the ultimate end game. If that’s all you’re after, you’re probably missing the forest for the trees.

Any use of government force should concern us and be carefully scrutinized. Deadly force all the more so. In a society governed by the rule of law, there is no room for obfuscating the facts, avoiding legal responsibility, or ignoring violations of rights for mere political convenience

One of the best things you can do for a friend is remind them life rarely moves in a straight line.

Something about AI hallucinating fake cases feels very familiar to anyone whose clients say things like “My friend, who’s a lawyer—well he isn’t practicing, but he went to law school—said that…”