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Moore & Bruce, LLP advises US, non-US and “multiple
nationality” families with respect to trust and estate
planning. The context is often not merely planning for the
death of an individual or couple but how they will live
their lives—life planning. The applicable rules are
especially complicated when applied to two or more
jurisdictions. As a practical matter, this subject overlaps
both tax and immigration and nationality law.
One of the skills required is the ability to convey a range
of technical information and common sense points to clients.
Sometimes this is made more difficult by cultural
differences. The attorneys at the Firm, by virtue of years
of experience, are able to do this effectively. US taxation
of foreign (i.e., non-US) trusts is a particular specialty.
The Firm advises a number of foreign banks and trust
companies with respect to these subjects.
We are known for advising individuals that may wish to
renounce their US citizenship (these are often individuals
that were dual nationals at birth) or to immigrate to the
US, becoming US resident aliens for income tax purposes,
sometimes US residents (domiciliaries) for estate and gift
tax purposes) and sometime US citizens.
In addition to providing a wide-range of US individuals and
families with traditional will and trust drafting services,
we have recently been engaged in the following projects:
- Redrafting a series of Bermuda trusts to conform to
recent changes in the manner in which US-resident
beneficiaries are taxed on trust distributions.
- Creating a family gifting program, including family
limited partnerships, to maximize the annual gift tax
exclusion.
- Structuring significant lifetime charitable gifts to
balance income requirements and estate and income tax
reduction strategies.
- Advising a non-US private bank and one of its
European clients on mitigating US estate tax on US
Foreign Investment in US Real Property holdings.
- Estate planning for a US family that controls
Australian companies.
- Estate planning for a mixed US and German couple
with holdings primarily in Germany.
- Advising as to catching up with filing of US tax
returns and Foreign Bank Account Reports and
renunciation of US citizenship by an “accidental
American” who was born in the US to Swiss parents but
never lived in the US after age 9 months.
- Advising a US “long-term” resident as to the
relinquishment of her US “greencard”
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