Strangi's Stranglehold On Offshore Planning

In the months since the Tax Court's decision in Estate of Strangi v. Commissioner (Strangi II) much has been written about its impact on estate planning, especially using family investment entities. But none of the literature discusses the implications for offshore families who invest in the United States. Yet Strangi II and, more importantly, the trend it represents might be one of the most important

In the months since the Tax Court's decision in Estate of Strangi v. Commissioner (Strangi II) much has been written about its impact on estate planning, especially using family investment entities. But none of the literature discusses the implications for offshore families who invest in the United States. Yet Strangi II — and, more importantly, the trend it represents — might be one of the most important developments in offshore planning in years.

As those who advise of

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