German Federal Fiscal Court Ruling on Gift Tax triggered by Distributions from a Foreign Trust

In its decision dated June 25, 2022, file no. II R 31/19 the German Federal Fiscal Court (Bundesfinanzhof) held that distributions from a Foreign pool...

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German Federal Fiscal Court: Assets titled in Trust to which the Grantor has reserved comprehensive Powers are to be considered owned by him for German Inheritance and Gift Tax Purposes

The German Federal Fiscal Court (Bundesfinanzhof) has held in its judgment of June 25, 2021, file number II R 13/19, that assets in a trust to which...

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Decicison of the German Federal Fiscal Court on the Taxation of Distributions from a 401(k) to Beneficiary in Germany

1) Distributions from a 401(k) are other income pursuant to Section 22 No. 5 Sentence 1 of the German Income Tax Act (Einkommensteuergesetz, EStG).

2...

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Concerns about a reduction in the U.S. Estate and Gift Tax exclusions? Make a gift now to benefit from historical exclusion levels.

The U.S. Treasury provided clarity for estate planners and their clients by issuing regulations that confirm that individuals who make gifts now...

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The Curtailing of Stretch IRAs

Effective January 1, 2020, the use of IRAs as an instrument for passing a stream of income tax free or tax deferred withdrawals will be limited to ten...

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German Gift Tax on Distributions from a U.S. Trust to a German resident Subsequent to an Election under Art. 12 para 3 of the Germany-U.S. Estate and Gift Tax Treaty

On March 6, 2019 the Ministry of Finance of Brandenburg published a binding decision on the taxation of distributions from a U.S. trust subsequent to...

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German Federal Fiscal Court Ruling on Taxation of Distributions from a Foreign Family Foundation and a Foreign Trust

In its decision dated July 3, 2019, the German Federal Fiscal Court (Bundesfinanzhof) held that distributions from a foreign family foundation...

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Taxation of Distributions from an 401(k) to an individual Resident in Germany

In its decision dated August 9, 2018, the Fiscal Court of Cologne (Finanzgericht Köln) held that for German residents taxation should be limited to...

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Estate Tax: Effect of the Tax Cut and Jobs Act on German Domiciliaries

On December 22, 2017, Public Law 115‑97 ("Tax Cuts and Jobs Act") was enacted. Sec. 11061 of the Act more than doubles the estate and gift tax...

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Estate, Gift and Generation Skipping Transfers Tax Exemptions 2017 Update

Federal Estate Tax

The estate tax exclusion for 2017 has been raised from

  • $5.45 million for individuals and $10.9 million for married couples in...
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