Family members – Hilpers http://hilpers.org/ Wed, 01 Dec 2021 02:45:44 +0000 en-US hourly 1 https://wordpress.org/?v=5.8 https://hilpers.org/wp-content/uploads/2021/10/cropped-icon-32x32.png Family members – Hilpers http://hilpers.org/ 32 32 3 family members killed in Thanksgiving crash on I-70 near Genoa https://hilpers.org/3-family-members-killed-in-thanksgiving-crash-on-i-70-near-genoa/ Wed, 01 Dec 2021 01:25:00 +0000 https://hilpers.org/3-family-members-killed-in-thanksgiving-crash-on-i-70-near-genoa/ Elaine Lopez and her sons Dominic and Jonathan died Thursday morning when their SUV crashed into I-70 east of Limon. FORT COLLINS, Colo .– The vacation weekend is over, but a family in Fort Collins can’t bear to go their separate ways. “We’re a little tight against each other,” said Alex Rangel. “Just kind of […]]]>

Elaine Lopez and her sons Dominic and Jonathan died Thursday morning when their SUV crashed into I-70 east of Limon.

FORT COLLINS, Colo .– The vacation weekend is over, but a family in Fort Collins can’t bear to go their separate ways.

“We’re a little tight against each other,” said Alex Rangel. “Just kind of leaning on each other.”

Rangel and those close to him need each other more than ever. On Thanksgiving morning, Rangel lost three of his family in a car crash on Interstate 70.

“We didn’t know what to do,” Rangel said. “Emotions fly. We just tried to be there for each other. We comforted each other. Said a prayer.

On Tuesday, the family gathered inside the house owned by Rangel’s aunt, Elaine Lopez.

On Thanksgiving morning, Lopez and his sons Dominic, 27, and Jonathan, 20, left their Fort Collins home to meet the rest of the family in Burlington.

“We kept calling, kept calling,” Rangel said. “There was nothing like them.”

Colorado State Patrol said the family were in a 2006 Ford SUV heading east near Genoa. At 10:50 a.m., the SUV pulled off the road, struck a sign, skidded and rolled down the freeway, CSP said.

Lopez and his sons died in the crash. The driver of another SUV joining I-70 westbound was slightly injured.

Rangel said his grandparents were the first to know about the crash. He and the rest of the family heard the news from his uncles.

“It was hard, man,” he said, his eyes filling with tears. “It was hard.”

Rangel said his aunt’s house was often the site of Thanksgiving dinners and Christmas gatherings.

“She was probably the most loving of all of us,” Rangel said. “She was the nicest person you can be.”

Rangel remembers the good times he spent with his cousins, making hay bale forts and playing hide and seek. He said his cousin, Dominic, was “goofy” and the kind of guy known for “photobombing” family photos. Rangel said he remembers Jonathan as a lovable child who grew up loving playing video games and talking about politics.

“They were fun to be around,” Rangel said. “It’s certain.”

On Tuesday, photos of Elaine, Dominic and Jonathan covered tables inside the Fort Collins home. A 4 month old baby girl named Elaine cooed in her mother’s arms.

“They named her after Elaine,” Rangel said.

The youngest of the family never had the chance to meet her namesake and her great aunt, but she will hear stories about how much she was loved.

“We all loved them very much, and they loved us too,” Rangel said.

The family is planning services to put three of their loved ones to rest. They created a GoFundMe to help cover expenses.

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Family of man injured in Palm Springs Thanksgiving shooting speak out https://hilpers.org/family-of-man-injured-in-palm-springs-thanksgiving-shooting-speak-out/ Sat, 27 Nov 2021 20:05:54 +0000 https://hilpers.org/family-of-man-injured-in-palm-springs-thanksgiving-shooting-speak-out/ A man shot dead in Palm Springs on Thanksgiving night is recovering and is expected to survive. Palm Springs police confirmed on Friday morning that shortly after 10 p.m. Thursday night, the victim left her daughter’s home and began driving Granada Avenue from Palm Vista. Police said that when the man walked past a group […]]]>

A man shot dead in Palm Springs on Thanksgiving night is recovering and is expected to survive. Palm Springs police confirmed on Friday morning that shortly after 10 p.m. Thursday night, the victim left her daughter’s home and began driving Granada Avenue from Palm Vista.

Police said that when the man walked past a group of people standing on a street corner near this intersection, he started hearing gunshots and realized he had him- even been shot. The victim went to hospital with non-life threatening injuries.

The victim’s daughter, Miriam Bravo, and her son-in-law, Andre Bravo, have said gun violence in their neighborhood must end. Miriam said she was lucky her father was still alive after being shot in the leg. However, other shootings in the neighborhood proved fatal.

“Being able to stand here today and say that I’m here with my dad and he’s alive is something these people can’t say anymore,” Miriam said. “I can’t even show my son how to ride his bike in our own community because I don’t know who will be around the corner.

The Bravos said gun violence in their neighborhood happens too often, especially during the holiday season. As Christmas approached, they said they were worried.

“You know, we’re planning to celebrate and now it’s, you know, we’re wondering, isn’t it?” Said Andre. “You know our dad just got shot… put the same emphasis on the neighbor. Let’s take care of each other.

The couple advocate for responsibility and change for their community. They suggest regular police patrols in the area.

“If we know these things are happening, most of the time at these times, why not be here before they can happen?” Andre said.

Other residents of the surrounding area said they were also looking for peace.

“I mean, we get together and talk to your neighbors, the police wave and talk to our community and treat us like human beings. That’s all we ask, ”said resident Shawnda Thomas Faveau.

Palm Springs Police are asking anyone who may have been in the Palm Vista and Grenada area and witnessed the shooting or have information about the shooting to call 760-327-1441. Information may also be reported anonymously to CrimeStoppers at 760-341-7867.

“I’m grateful my dad is with me, but you know I’m done. We are done, “said Miriam.” We need the community to speak up. We need the community to come together and be a neighbor and no longer just a hood. “


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Members of the Brewster family visit historic Brewster’s Neck Cemetery in Preston https://hilpers.org/members-of-the-brewster-family-visit-historic-brewsters-neck-cemetery-in-preston/ Sat, 27 Nov 2021 01:41:04 +0000 https://hilpers.org/members-of-the-brewster-family-visit-historic-brewsters-neck-cemetery-in-preston/ November 26 – PRESTON – The descendants of Mayflower’s passenger, the eldest William Brewster, were on the phone a few weeks ago, planning a meeting, a little disappointed that COVID-19 scuttled plans last year for the big celebrations of the 400th anniversary of the Mayflower landings. “I looked at the calendar and said, ‘Oh my […]]]>

November 26 – PRESTON – The descendants of Mayflower’s passenger, the eldest William Brewster, were on the phone a few weeks ago, planning a meeting, a little disappointed that COVID-19 scuttled plans last year for the big celebrations of the 400th anniversary of the Mayflower landings.

“I looked at the calendar and said, ‘Oh my God, we have the original 400th anniversary of Thanksgiving coming up! “said Bill Endicott of Bethesda, Maryland, recalling the phone call with Dr. Russell Bingham of Old Lyme.

About 15 descendants of the Mayflower Brewster celebrate the anniversary with a three-day tour of historic sites, both family and country.

On Thursday, the group gathered for a traditional Thanksgiving dinner at the historic homestead, Mumford House in Salem. The 252-year-old home, which has remained in the hands of the Brewster-Bingham families, hosts many visits and family reunions.

Chef Joseph A. Hanson, 37, professional chef at Superfine restaurant in Brooklyn, NY, cooked the 10-hour brine turkey, traditional bread stuffing, squash, and honey squash soup. Anne E. Bingham of Salem made Indian pudding and Anne Bingham Pierson of Old Lyme brought 48 jars of four flavors of jam – quince, marmalade, spearmint and blueberry.

16 other family members joined a Zoom Online session from afar.

The cool November rain on Friday morning didn’t slow down family members, as they loaded into a white van and carpooled to historic Brewster’s Neck Cemetery at Preston’s former Norwich Hospital.

Jonathan Brewster, William Brewster’s eldest son, arrived in the New World a year after the Mayflower landings. He settled in New London in 1648-1649 and soon settled on the east bank of the Thames, a place which became known as Brewster’s Neck, where the Mohegan tribe granted him 50 square miles on condition that he operates a trading post with native residents.

Jonathan Brewster, who died in 1661, and many descendants are buried in the cemetery, with some gravestones dating from the late 1600s and early 1700s.

Russell Bingham inspected the cemetery two weeks before Friday’s tour. He guided visitors to the great Brewster Monument, erected by the family’s descendants in 1855 on the site of Jonathan Brewster’s grave. The monument includes “broken fragments” inlaid from its original gravestone, according to an engraving on the monument.

“This part of the stone was the original gravestone for his death in 1661,” Bingham said, as several family members leaned in for a closer look. The name, Jonathan Brewster, remains legible on the bronze-colored fragment.

“In memory of Lucretia Brewster, member of the Mayflower Company in 1620,” says another side of the monument, describing Jonathan Brewster’s wife. “A noble specimen of a kind, enlightened and heroic Christian woman, who died around the year 1671.”

Grabbing umbrellas, family members wandered around the small graveyard and located other readable Brewster Stones. Eloise Bingham Goddard of East Hampton, Mass., And her son, Sameer Hiram Goddard, noticed two simple rounded stones with large capital letters that filled the entire space with some words carried over to the next line. She noted that the name was spelled BRVWSTER on a stone from 1709.

“I want a gravestone like this,” she said, “for people 200 years from now to be looking at it laughing, like we are today.”

After visiting the cemetery, members of the Mohegan tribe joined the Brewster family at the cemetery to talk about history and the future.

Mohegan Gaming & Entertainment, the tribe’s development entity, is expected to take ownership of 393 acres of the former Norwich Hospital property in Preston after the town completes an environmental cleanup. The tribe is planning a major non-gaming commercial, retail, sports and entertainment complex there.

Mohegan Tribal Councilor Mark Brown said before meeting with the family that Brewster Cemetery and three other historic cemeteries on the former Norwich Hospital property would not be part of the deal. Brown said the tribe would ensure that natural buffer zones protect the cemeteries and that visitor access to the cemetery is maintained.

Brown called Jonathan Brewster “a friend of the Mohegans”.

Members of the Brewster family will continue their Thanksgiving weekend tour on Saturday with a trip to Plymouth, Mass., Where the Mayflower Company settled in December 1620 after first landing at the tip of Cape Cod. They will visit a museum that contains Brewster artifacts, visit the replica of the Mayflower II ship and have “a great group lunch,” Endicott said.

The group won’t have time to make it to Provincetown, where a small park and a plaque mark the Mayflower’s first landing spot. He hopes to make it part of a future family reunion.

“We have to get there,” he said.

c.bessette@theday.com


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Gifts for your relationship circles, from family members to acquaintances https://hilpers.org/gifts-for-your-relationship-circles-from-family-members-to-acquaintances/ Wed, 24 Nov 2021 17:18:19 +0000 https://hilpers.org/gifts-for-your-relationship-circles-from-family-members-to-acquaintances/ While the holiday shopping is in full swing, you may both know exactly what to get some people and be completely bewildered by others. Determining the gifts from your different relationship circles is definitely one thing. For example, you know your best friend collects tea cups, so it’s pretty easy (and fun) to find one […]]]>

While the holiday shopping is in full swing, you may both know exactly what to get some people and be completely bewildered by others. Determining the gifts from your different relationship circles is definitely one thing. For example, you know your best friend collects tea cups, so it’s pretty easy (and fun) to find one that she doesn’t have. Yet when it comes to a new friend or a working acquaintance, what about then? You might not know them as well, so finding a unique gift can be more of a challenge.

“There is no such thing as a ‘perfect’ gift, so once you give it up, you can enjoy gifts without stress. ” Aileen Avery, author of Gift Rap: the history and art of gifting, TZR said in an email. “A little planning ahead will also go a long way in making the gifting season easier and happier. »Mercedes Sanchez, lifestyle expert from Be chic, adds that whether it’s shopping for a loved one or an acquaintance, choosing the right gift can be difficult. “On the one hand, you don’t want to offend them with a boring article, but you also shouldn’t overspend,” she told TZR in an email. When looking for a gift, think about how long you’ve known the person and how deep your current relationship is. To help you make the right choice, ask yourself the following question: “Was the choice of gift useful, thoughtful and on budget?” “

Whatever your spending limit this year, below, gift experts share some recommendations for gifts to give to each type of person in your life – yourself, intimate partner, family members, friends, acquaintances. and even the occasional foreigner.

We only include products that have been independently selected by TZR’s editorial team. However, we may receive a portion of the sales if you purchase a product through a link in this article.

Yourself

Yes, you should treat yourself to a little something this year (and every year). Lindsay Roberts Schey, Founder of TheGiftInsider.com, says wellness gifts are huge when it comes to giving yourself. “We love gifts that focus on your health and well-being, especially these days,” she told TZR in an email. “Aromatherapy diffusers, hobby sets and Bala bracelets are all excellent. We’re also big fans of “happy gifts” – a hot pink Apparis blanket, the latest Lele Sadoughi headband, or silk pajamas – something you might not splurge on for the rest of the year. ”

Elisabeth Jones-Hennessy, founder and CEO of GiftMeChic.com, also has an idea of ​​what you can afford. She says she enjoys wellness, spirituality and self-care very much, and talks to her tarot card reader every few months. “She amazes me every time – she is unbelievableJones-Hennessy told TZR in an email. “Everyone I know who has had a session with her calls me panicked because she is so talented and connected to the spiritual world. If someone offered me a session with her, I would be delighted. ”

Avery also says taking care of yourself is so important these days and we should all indulge in the little pleasures in life. She recommends giving yourself something like an audio subscription, like Audible, to listen to your favorite books or find new ones. (You can currently get a month free.) Or you can prefer a massage, facial, manicure / pedicure, or even goat yoga. “You can’t help laughing at that one,” she said.

Sanchez also offers a wellness gift and thinks the end of the year is a great time to consider your financial goals. “If you want a holistic approach to financial well-being, consider booking a Reiki Money session, ”she said. “I recently treated myself to a virtual session (body scan and all), and I don’t regret it. I can’t wait to put my new clarity into practice.

Intimate relationship

When it comes to buying gifts for your partner, these are the type of gifts to think about long, says Roberts Schey. “Think about what kind of person they are and what they really like and go from there,” she says. “You want them to open the gift and know that you chose it just for them.” Some ideas she recommends include a Theragun for fitness fanatics, a photo gift from Artifact Uprising, or an experience gift, like a bourbon or tequila tasting you can do together. “If you’re new to a relationship, getting to know the other person is so much fun,” says Avery. “A game like The Adventure Challenge will help you (and they have a naughty version too).” She, too, thinks a photo gift is a good idea if you’ve been in a relationship for a while. “Creating a photo book of all the moments of your life together will remind both of you why you’re always together,” she says.

Sanchez adds that when it comes to a gift for your partner, consider giving them something that literally brings you closer. “Aromatherapy via a rose body massage The oil has several benefits, including relaxation and feeling soft on the skin. And don’t forget a personalized card to top it off, says Jones-Hennessy. “Handwritten cards and love notes are super special, meaningful and can be kept for a lifetime. Cardeux is my favorite brand for everything stationery, ”she says.

Family

When looking for the perfect gift for your family, Roberts Schey says all you need is one thing: fun. This can include ideas for game nights, karaoke machines, fondue kits, etc., she says. “Smart home gifts are also always a great way to go,” she adds. “Nest cameras, an Amazon Echo, or Ring cameras are all great gifts for family members.” Sanchez says you might also want to help a family member on their wellness journey. “Right now there is a buzz around the Oura ring,” she said. It’s a unisex ring that measures your heart rate 24 hours a day. “It uses data points, as well as an accelerometer to detect movement and track your sleep and activity,” she adds. “It then transmits your results to a companion app via Bluetooth. “

Avery says that when it comes to choosing gifts for family and friends, she always tells people to listen carefully throughout the year. “People always tell you what they want with statements like ‘Someday I’m going to have…’ or ‘I like the smell of this lotion! Write it down and you’ll have a ready-made Christmas list.

Friends

When shopping for friends, Roberts Schey says this is where you want to go the extra mile and deliver something personalized or chosen just for them. She recommends a personalized AirPod case, beaded bracelets or barrettes with their name on it, a personalized jewelry travel case, or a fun candle that simply screams “Pick just for you!” “

Jones-Hennessy says she loves giving gifts to her friends. “I hope you know your friends enough to really find things that are meaningful and personal to you,” she says. Avery also says the “friends” gift category is his favorite. “You should know your friends really well, and if you’re careful you know what they like,” she says. For the friend who enjoys cooking and gardening, she suggests a book like The renewal of the vegetable garden. For someone who has everything and loves getting mail, she recommends The Mysterious Package Company, which sends them a themed package, from adventure to sci-fi to horror (and more). And for a socially conscious friend who loves artisanal goods, you can gift him a bowl of noodles (which he can use for a lot of things, not just noodles).

knowledge

Giving gifts to acquaintances can take a bit of homework as they can fall into a number of categories: neighbor, colleague, dog walker, etc. “Or, even in the broadest sense, think about what you know about them or things they have told you about themselves. She recommends these Assouline travel diaries, which cover a wide range of interests including travel, writing and luxury in an affordable, colorful and cheerful way. Edible gifts are also a great way to socialize, says Roberts Schey. “We like to find things that are unique and a bit under the radar,” she says. Some of the fun ideas she suggests include festive candy boards, s’mores kits, and NYC spots (personalized giant marshmallows). Homemade baked goods are also a great way to go.

Avery agrees, saying that things to eat, like handmade chocolates or a gift card at a local cafe (a place they frequent), are must-have gifts for acquaintances. “This group will likely include people like your letter carrier and your child’s teacher,” she says. “You don’t need to overspend, but be sure to include a handwritten note to express your gratitude and holiday wishes.” Sanchez also recommends not spending too much, but choosing a safe and affordable gift, perhaps something they can use at home or in the office. “Zoom calls aren’t going anywhere right now,” she says. “With this WorkRobe, you can turn on your webcam in your loungewear without worrying about looking unprofessional.”

Foreigners

Jones-Hennessy says giving gifts to strangers can be a challenge, so it’s best to stay safe and get something that most people generally like, like this House of Waris Botanicals or the Mr. P’s Jam Trio gift box. “You can’t go wrong with soothing decaffeinated tea or delicious homemade jam,” she says. Sanchez also recommends getting something fairly general that most people would like. “As far as foreigners go, I recommend keeping the giveaway simple and the costs low,” she says. “On Amazon, you can find a lot of freebies under $ 15! For example, who doesn’t love cozy throws this time of year? Even if you don’t know the person well, or not at all, a sherpa blanket can be used in a freezing cold office or even for watching your favorite shows from the couch.

Another gift idea that Sanchez has is to get a scheduler or planner. “It will never go out of style,” she says. “Even in this digital world, many prefer to jot down dates in an old-fashioned calendar.” And Roberts Schey says she doesn’t necessarily recommend giving gifts to strangers. But if you do, an edible gift or gift card is always a safe bet to somewhere accessible to everyone, like Amazon, Target, etc. And you can always pair it with an edible treat, such as hot chocolate bombs or an s’mores kit.



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Foreign Grantor Trusts: Planning Non-U.S. Family Trusts – Corporate / Commercial Law https://hilpers.org/foreign-grantor-trusts-planning-non-u-s-family-trusts-corporate-commercial-law/ Mon, 22 Nov 2021 10:03:27 +0000 https://hilpers.org/foreign-grantor-trusts-planning-non-u-s-family-trusts-corporate-commercial-law/ To print this article, simply register or connect to Mondaq.com. Trusts are often used by successful families for long-term estate planning and centralized asset management. However, US tax rules can negatively impact US citizens, green card holders, and tax residents who benefit or may even benefit from income and capital gains in non-US trusts (and […]]]>

To print this article, simply register or connect to Mondaq.com.

Trusts are often used by successful families for long-term estate planning and centralized asset management. However, US tax rules can negatively impact US citizens, green card holders, and tax residents who benefit or may even benefit from income and capital gains in non-US trusts (and their holding companies under -jacent). Non-American patriarchs and matriarchs with American family members, however, can significantly improve the situation of their American family members through the establishment of a “Foreign Grantor Trust” (hereinafter “FGT”).

Benefits of an FGT

A properly structured and administered FGT offers very favorable U.S. federal tax treatment to U.S. family members, including:

  • No annual tax or declaration of income or earnings of the trust (unless from US sources) during the settlor’s lifetime;
  • No annual tax or declaration regarding investments classified as passive foreign investment companies (“PFIC”) and / or entities that might otherwise be classified as controlled foreign companies (“SEC”) during the grantor’s lifetime;
  • Non-taxable distributions to U.S. family members during the grantor’s lifetime (although a payee disclosure requirement applies); and
  • Elimination of future US gift and inheritance taxes on trust assets (provided that the assets located in the US, if any, are held through a non-US holding company classified as a corporation for U.S. tax purposes).

Disadvantages of outright gifts and non-ceding foreign trusts

These advantages are particularly attractive compared to the outright transfer of assets to US family members or the current investment of assets in a trust that does not qualify for FGT status. Assets currently transferred to:

  • U.S. family members would be subject to tax on future income and gains generated by those assets and would become subject to the U.S. gift and inheritance tax system which currently imposes a tax rate of 40% on the estate. value of assets of future donations or bequests made by American family members.
  • Any non-US trust other than one qualifying for “foreign grantor trust” status would be classified as a “non-grant foreign trust” and would generally subject US family members to current year income tax and income tax. gains distributed to them and unfavorable tax rates and compound interest charges on undistributed trust income and gains in the year of realization and could result in tax and / or reporting obligations for US family members in respect of any PFIC or CFC assets held by the trust.

Structuring Trust for Other American Considerations

While in many circumstances it should be relatively straightforward to structure a trust to achieve FGT status, there are a number of related but additional considerations relating to the drafting and structuring of the trust that must be taken into account. :

  • If U.S. family members are granted certain powers or rights under the trust, this could subject them to U.S. income or gift or estate tax either during the settlor’s lifetime or after the settlor’s death. .
  • If the trust directly holds assets located in the United States, those assets will generally be subject to U.S. estate tax upon the death of the settlor (and to gift tax if transferred to family members of the settlor. living of the constituent).
  • If the settlor directly owns assets located in the United States and transfers those assets to the trust, then on the death of the settlor there will generally be US inheritance tax on the trust even if those assets had been sold there long and that the trust did not directly or indirectly own any assets located in the United States at the time of the settlor’s death.
  • Such exposure to inheritance and gift tax can generally be avoided through the use of a non-US holding company to hold assets located in the United States.
  • In most cases, it will be desirable to structure the FGT such that the assets directly held by the trust automatically receive a “base increase” to the current market value upon the death of the settlor. On a subsequent sale of these directly held assets, the amount of the gain realized by the trust will be reduced, thereby reducing the amount of tax payable on distributions to US family members.

Following the death of the settlor

Following the death of the settlor, the FGT will automatically switch to the status of “non-granting foreign trust” (hereinafter “FNGT”). At that point, leaving aside additional considerations regarding fiduciary assets classified as PFIC or CFC, in a very general way,

  • Income and distributed earnings during the year made to American family members would generally be taxed to them as if those amounts had accrued directly to those individuals; and
  • Income and gains made but not distributed until a later year to U.S. family members would generally be subject to tax under the so-called “retroversion” rules as “undistributed net income” (“UNI”), these amounts are generally taxable on ordinary income. even though they were originally capital gains, and generally subject to additional interest charges compounded over the period in which those amounts accumulated in the trust.

Holding companies

Rather than directly owning investment assets, non-US trusts will frequently choose to use a non-US holding company to hold those assets. In addition, as noted above, with respect to assets located in the United States, it is generally true that these assets should be held through a non-US holding company in order to eliminate exposure to US inheritance tax that would generally apply to those assets located in the United States. . Using a holding company, however, can create tax complications for recipient US family members with respect to the grantor’s death.

Based on all the facts and circumstances at the time of the settlor’s death, if more than half of the ownership of the holding company is attributed through the trust to members of the United States family, that holding company would generally be classified as a CFC, creating a U.S. tax and return. considerations for U.S. family members with respect to income and earnings generated within the holding company after the settlor’s death.

Prior to 2018, it was generally true that (after the grantor’s death) continued CFC tax exposure for U.S. family members could be eliminated by filing an election called a ‘tick the box’ to deal with the corporation. holding as liquidated / ignored for the United States. for tax purposes in a manner that does not create SEC tax exposure for U.S. family member beneficiaries while protecting U.S.-based assets held by the holding company from tax exposure US estate in connection with the grantor’s death.

However, under current legislation, this choice to ‘tick the box’ could now itself generate a CFC tax for U.S. family members (typically measured by reference to the amount of earnings embedded in family assets. holding company and at the time of the year when the settlor passed). Thus, if the holding company has a mix of assets located in the United States and not in the United States, in the absence of additional planning, the tax cost of protecting the assets located in the United States from exposure to Inheritance tax will generally be a one-time CFC tax exposure for US family members following the death of the settlor.

In cases where the holding company does not own any assets located in the United States, it should generally be possible to make a checkbox choice in a manner that does not expose members to CFC tax for members. family in the United States.

Assuming that it is not possible to eliminate the assets located in the United States, several strategies can then be considered, all of which would improve the position in different ways, including:

  • sell and repurchase assets annually in order to “enhance” the holding company’s base in those assets;
  • isolate the assets located in the United States in a separate non-US holding company (which holding does not itself hold any non-US assets); and
  • create certain types of multi-level holding structures to allow the implementation of the checkbox choices in a way that should itself allow most, but not necessarily all, of the appreciation of the assets to escape taxation under CFC rules.

Where the trust holds (directly or indirectly) substantial interests in “trading companies” or “operating companies”, other CFC considerations may apply.

PFIC

Depending on all the facts and circumstances following the death of the settlor, if the trust holds PFICs (directly or through or in respect of holding companies), the beneficiary members of the U.S. family could be subject to taxes and compound interest when these PFICs are transferred or these PFICs themselves make distributions (potentially even though these amounts are not even currently distributed to beneficiary US family members). In fgeneral:

  • holding companies through which trusts indirectly hold investments may themselves be classified as PFICs. For example, an investment asset holding company that is not classified as an SEC may be classified as a PFIC.
  • Most non-US mutual funds such as non-US mutual funds, non-US ETFs, non-US hedge funds, and some non-US private equity funds will be classified as PFICs.

How best to deal with PFICs will depend on a number of factors, including the makeup and needs of US and non-US family members, whether the trust has been structured to qualify for a base increase, how the PFICs were held (for example, if through a holding company, also owned donkeys located in the United States) and how the checkbox planning is implemented in connection with the settlor’s death.

Planning opportunities

We would be delighted to discuss how best to tailor a “foreign transferor trust” structure to the particular facts and circumstances of each family.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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Family members of mass shooting at FexEx plant to sue Indianapolis for $ 2.1 million | New https://hilpers.org/family-members-of-mass-shooting-at-fexex-plant-to-sue-indianapolis-for-2-1-million-new/ Wed, 17 Nov 2021 15:57:00 +0000 https://hilpers.org/family-members-of-mass-shooting-at-fexex-plant-to-sue-indianapolis-for-2-1-million-new/ LOUISVILLE, Ky. (WDRB) – Three members of the Sikh community are now considering suing the city of Indianapolis for $ 2.1 million in damages following the deadly shooting at a FedEx facility in April that killed eight people. According to a report by FOX 59, the lawsuit seeks compensation from the city for failing to […]]]>

LOUISVILLE, Ky. (WDRB) – Three members of the Sikh community are now considering suing the city of Indianapolis for $ 2.1 million in damages following the deadly shooting at a FedEx facility in April that killed eight people.

According to a report by FOX 59, the lawsuit seeks compensation from the city for failing to file a complaint against the shooter, Brandon Hole.

Indiana’s “red flag law” allows police or courts to seize the firearms of people who may commit acts of violence. It became law in 2005 after Indianapolis policeman Jake Laird was killed by a man whose guns were returned after the individual had mental health issues.

In March 2020, Hole’s shotgun was confiscated after his mother called the police over concerns about her son’s mental instability. Sheila Hole told FOX 59 that Brandon had threatened to kill himself on several occasions and said he wanted to commit suicide by cop. But ultimately, prosecutors did not file a petition with the court to determine if Hole was a continuing threat, which would have barred him from purchasing more weapons.

The shooter’s mother told FOX 59 that she believed the concerns that led police to seize Brandon’s gun should have prevented him from being able to purchase more guns in the future.

Plaintiffs in the lawsuit accuse the IMPD and the Marion County Attorney’s Office of violating this requirement of Indiana’s red flag law when they decided not to bring a lawsuit to the courts to stay Brandon Hole gun usage rights in March 2020.

The misdemeanor claims that the IMPD did not submit an affidavit after Hole’s gun was taken and the Marion County District Attorney’s Office did not request a hearing, “denying court the opportunity to review an affidavit and hold a subsequent hearing to determine whether Mr. Hole should be temporarily denied access to his firearm and / or be prohibited from purchasing or owning another firearm during the duration of the protection order, as required by law. “

Marion County District Attorney Ryan Mears said in April that because the shooter had surrendered his gun there was no reason to pursue the case.

The shooter then legally bought two rifles a few months later, which he used to kill eight former co-workers.

In the letter from the victims’ lawyers to the town’s lawyers, dated October 12, each of the three plaintiffs asked the town for $ 700,000 in damages.

Four members of the Sikh community, Amarjit Sekhon, Jasvinder Kaur, Amarjeet Kaur and Jaswinder Singh Bains, died in the shooting. Several other people who survived the shooting are also members of the Sikh faith.

FOX 59 has contacted the legal team responsible for the trial of members of the Sikh community, who have provided the statement below.

“We are legally required to provide adequate notice to the City of Indianapolis and Marion County within a certain time frame to protect the rights of our clients if they decide to go ahead with a lawsuit related to the tragedy of last April. Accordingly, we submitted this notice of complaints last month to comply with this obligation. We remain in close conversation with our clients about their injuries and their ongoing needs as we continue to chart the course and work on these issues. “- Winston & Strawn and the Sikh Coalition

The letter sent to the town’s lawyers serves as notice of the tort claim, the first step towards a formal trial.

Copyright 2021 WDRB Media. All rights reserved.


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WTAMU to Offer 50% Tuition Discount to Employees and Immediate Family Members | KAMR https://hilpers.org/wtamu-to-offer-50-tuition-discount-to-employees-and-immediate-family-members-kamr/ Mon, 15 Nov 2021 16:38:51 +0000 https://hilpers.org/wtamu-to-offer-50-tuition-discount-to-employees-and-immediate-family-members-kamr/ CANYON, Texas (KAMR / KCIT) – Beginning in the 2022 Summer One session, West Texas A&M University employees and eligible immediate family members will be able to receive a tuition reduction. According to a press release from the university, these people will be entitled to a 50% reduction in tuition and fees. Officials say this […]]]>

CANYON, Texas (KAMR / KCIT) – Beginning in the 2022 Summer One session, West Texas A&M University employees and eligible immediate family members will be able to receive a tuition reduction.

According to a press release from the university, these people will be entitled to a 50% reduction in tuition and fees. Officials say this waiver was developed, in part, to thank employees through their work during the COVID-19 pandemic.

“The positive path the university is on right now is made possible by the exemplary work of many people on campus,” said Neil Terry, executive vice president and president of the university, in the statement. “Additionally, we know that working at the university creates an explicit bond for faculty and staff, but an individual or family member who graduates from WT further strengthens that institutional bond significantly.”

Officials say full-time employees and their dependents can use the waiver to pursue a first bachelor’s, graduate, or second master’s or doctorate degree. But the waiver cannot be used for certificate programs, applicable non-diploma courses or second bachelor’s degrees, as well as books, school supplies, accommodation or meals.

University officials see the discount as an incentive to join the staff at West Texas A&M University, thereby encouraging their children to pursue graduate studies at the university as well.

“As a higher education institution, it is essential that we encourage and support higher education for our employees and their families,” WT President Walter Wendler said in the statement. “Retaining the highest level of faculty and staff is a key part of our long-term plan, WT 125: From Panhandle to the World, and we believe this new advantage will be key to our ongoing recruiting efforts.


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Kenya: land dispute ends funeral of 3 family members killed in road accident https://hilpers.org/kenya-land-dispute-ends-funeral-of-3-family-members-killed-in-road-accident/ https://hilpers.org/kenya-land-dispute-ends-funeral-of-3-family-members-killed-in-road-accident/#respond Thu, 11 Nov 2021 13:06:37 +0000 https://hilpers.org/kenya-land-dispute-ends-funeral-of-3-family-members-killed-in-road-accident/ The burials of a man, his wife and their daughter who perished in a road accident on November 1 in Kiambu county did not take place in Murang’a on Wednesday as planned, due to a land conflict. The bodies were taken on a road trip to the Anglican Church in Gakurwe, where a mass was […]]]>

The burials of a man, his wife and their daughter who perished in a road accident on November 1 in Kiambu county did not take place in Murang’a on Wednesday as planned, due to a land conflict.

The bodies were taken on a road trip to the Anglican Church in Gakurwe, where a mass was held before being returned to the morgue.

The bodies had been removed from the Montezuma Monalisa funeral home in Murang’a South and transported to Kiharu constituency for the planned burial.

Three graves that had been dug for them in the village of Gatitu were filled with earth by a wing of the family who did not want the ceremony to take place there.

William Kamau, 77, his wife Jane Njoki, 69, their two daughters Rhoda Njeri, 40, and Evelyn Waithira, 32, died when their car crashed in Njira ya Ngenia, near Limuru.

Ms Waithira, a tutor at Kenya Medical Training College, Nairobi, was driving the car.

Tigoni Traffic Police boss Benson Onsongo told Nation.Africa the crash happened when the driver, heading towards Nakuru, attempted to overtake another car and collided head-on with an oncoming vehicle.

Ms. Njeri was buried on Monday on her husband’s land in the village of Kariti, near the Mukurwe wa Nyagathanga shrine.

“We had informed the family members that we would not allow them to bury the bodies on this land,” said James Ngige.

“We gave them a court order to this effect which we had obtained from the Murang’a courthouse. But the arrogance and impunity made them want to force the burial.”

He said the deceased was given another land and ordered to settle there, but chose to live on the disputed plot.

“They deliberately put themselves in this shame to remove the bodies from the morgue, to organize a mass for them in a church and finally, for lack of graves, to bring them back to the morgue,” he said.

He added that the inner circle of the bereaved family had hoped to use the money to force the ceremony.

He said the family hired their own security to force the burial only for a court order to prevail and force area police to ensure the ceremony does not take place.

Mr Anthony Gichatha, a son of the grieving family, said “the incident was regrettable and unfortunate”.