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The universe of offshore tax planning and asset protection is large and complex. There are no "magic bullet" structures; instead there is a myriad of choices. The hallmark of a savvy practitioner is not only knowing of all the available options, but also knowing when to use which option for a particular client. Swiss annuities should be considered by all practitioners looking to confer significant tax and asset protection benefits on their clients.
The question of California registration comes up often when foreign limited liability companies are used as holding companies for California legal entities, or own passive assets in California like bank accounts and non-income producing real estate. In publication 3556, and in practice, the FTB has adopted a position that virtually every foreign limited liability company, especially one with a California resident manager or managing members should register with California and pay California taxes. The FTB, again, is wrong.
Dr. Mehta always encouraged his children to be entrepreneurial. So when his son undertook his first real estate development project, Dr. Mehta helped him by personally guaranteeing $1 million in loans.
As the Year Winds Down, Clients Finally Look to "Plan." There is a commonality shared by all tax practitioners - procrastinating clients. If we are fortunate, the client call will come in at 3 p.m. on the day a transaction is set to close. In many cases, the call comes in after the transaction has been completed, some time next tax year. What is a tax practitioner to do?
We often preach about converting existing corporations to limited liability companies, both for tax and non-tax reasons. If the conversion is effected for tax planning reasons, it generally results in a liquidation of the corporation and the contribution of the corporate assets to a limited liability company taxed as either a disregarded entity or a partnership.
Welcome to the introductory issue of our e-mail newsletter! Our newsletters aim to educate you on the subjects of our expertise: asset protection, tax law and business entities. These newsletters will endeavor to introduce you to various advanced planning strategies and will update you on new cases and developments. From time to time we will share with you some of our recent client stories and victories. We hope you will find these monthly newsletters interesting and useful.