Robert Payne, J.D., LL.M

Amicorp Services Ltd.
Miami, FL


I deal with international tax matters as they pertain to estate and tax planning.

Major issues encountered:

Cross-border tax planning for multinational corporations and high-net-worth individuals.

Years a Bloomberg BNA subscriber:

User for 30 years including firms that subscribed; individual subscriber for 12 years.

Bloomberg BNA products most often used:

Estates, Gifts and Trusts Portfolios; Foreign Income Portfolios; Delaware State Tax Suite; and Florida State Tax Suite

Real Problems. Real Solutions.

One of my clients is a very wealthy overseas family that has given each grown child a number of shares of highly restricted, closely held stock. One of the grown children, who lives in the United States, was trying to do estate planning in such a way as to remove the value of the securities from their U.S. taxable estate by asserting that they had never established domicile in the United States.

Based on prior experience in this area, I needed reinforcement based on my client's unique factual situation. So I turned to my Bloomberg BNA Estates, Gifts and Trusts Portfolios Library to reaffirm the current state of the law and to provide more guidance on the issue of when U.S. estate tax attaches to a non-U.S. citizen and what would constitute domicile declaration for non-U.S. estates. Thus, the research was necessary to clearly establish results in my client's situation.

My Bloomberg BNA Tax Management Portfolios™ provided me with more than enough information for the answer, which, despite the result being unfavorable, did provide my client with clarity to their family situation. Based on the support that the Estates, Gifts and Trusts Portfolios Library provided, I was able to point my client to alternative planning methods to resolve their dilemma.