Section 301 of the Heroes Earnings Assistance and Relief
Tax ("HEART") Act of 2008 added new sections 877A and 2801 to the Internal
Revenue Code ("IRC"). These sections
generally apply to any U.S. citizen who relinquishes his or her U.S.
citizenship and any long-term resident of the...
By Wendy M. Greenberg, Esq. , Morrison & Foerster LLP
It is not at all uncommon for our clients to make provisions for long-time
employees in their wills or trusts. Most
of the time, we don't think twice about these bequests, because we know that
our clients think of the beneficiaries as friends...