Wealth Tax Planning for U.S. and non-U.S. owners of closely-held businesses, investors in funds or private equity firms, hedge funds, and investment managers, and high net worth individuals with respect to U.S. gift and estate tax as well as international estate and inheritance tax issues. Frequently works with foreign counsel on evaluating the tax consequences and tax compliance issues related to dual residency, expatriation from the United States, state and city residency tax issues. Mr. August is frequently referred to clients by estates and trusts lawyers, trust companies and wealth advisors, and home offices throughout the country on estate planning and post-mortem tax issues and controversies, including, but not limited to, valuation disputes with the Internal Revenue Service and as well as fiduciary and transferee liability issues. A summary of such areas of involvement include:

  • Family Business Planning. Management succession and buy-sell agreements, recapitalizations of family owned corporations and partnerships, transfers to tax-exempt organizations and private foundations and estate planning for foreign based assets or business interests.
  • Personal Tax Planning. Working with executives, high net worth individuals and families on investments and interest in funds whether situated within or without the United States.
  • Planning For Minimizing the Impact of Project Death Taxes. Includes consideration of meeting the rules for special use valuation and deferred payments in tax. Consideration
  • International Tax Planning. Cross-border planning issues for clients who have migrated overseas or are not U.S. citizens and are domiciled in the United States. U.S. persons having property interests overseas.
  • Working with Foreign Counsel. In developing a multi-jurisdiction tax plan both for estate and inheritance planning, post-mortem structures such as trusts or private companies, and income tax planning including avoidance of double taxation.
  • Planning For Domestic Trusts Foreign Trusts and Estates. Includes income tax consequences to the trust and beneficiaries under U.S. income tax law with regard to applicable withholding and other tax reporting and compliance issues.