In the transfer tax context, the following categories of dual status clients can be distinguished asa U.S. citizen or U.S. domiciliary who is also deemed to be a transfer tax domiciliary of another country either by virtue of his or her nationality or residence (dual transfer tax resident); a dual income tax resident who is a non-U.S. domiciliary; and an NRA for income tax purposes who is a U.S. domiciliary. This white paper reviews these categories along with estate tax and gift tax considerations and discusses transfer tax treaties.
Partner and chairman of the Taxation and Estate Planning Group of Connell Foley LLP (Resident in the Roseland, NJ office)
Practice is dedicated to sophisticated tax planning for individuals, businesses, estates and trusts, with a particular emphasis on national and multinational estate planning, as well as as-set protection planning
Lectures extensively and frequently publishes in legal and business journals on a variety of tax and estate planning issues, including those related to federal estate, gift and income tax issues, wealth preservation, trusts, and a multitude of other planning techniques
Admitted to practice in six states, the District of Columbia and United States Tax Court
Recognized for the past 10 years in “Best Lawyers in America” in the areas of trust and estates, trust and estates – litigation, and tax litigation and controversy
LL.M. degree in taxation; J.D. degree, New York University