Thomas M. Giordano-Lascari

Private Client Services Partner, Thomas Giordano-Lascari, authored, "UN Wealth Tax Model Puts High-Net-Worth US Assets in Crosshairs" in Bloomberg Tax. Excerpts: The United Nations has offered a framework for countries that want to consider a wealth tax. For advisers of ultra-high net worth clientele in the US, a concern is the continued tendency of multilateral quasi-governmental bodies to push a “one ring to rule them all” uniform system of taxation with a net wealth tax being the latest policy du jour. That concern isn’t from a political point of view as to the merits of the policy objectives guiding the UN’s efforts, but rather from the perspective of a practitioner in the wealth planning space. Once a net wealth tax is ubiquitous in the domestic taxing legislation of a significant number of countries, the inevitable next step will be defining the reach of that tax, including extra-territorially. Read the full article here.

Private Client Services Partner, Thomas Giordano-Lascari, published the article, "Supreme Court Can Guide Congress in Foreign Earnings Tax Case" to Bloomberg Tax. Excerpts: In the tax world, the Supreme Court’s decision to hear arguments in Moore v. United States is a big deal because it challenges the constitutionality of a tax on foreign earnings known as a mandatory repatriation tax, or MRT, under Section 965 of the tax code. The plaintiffs argue that the MRT is a direct tax on property and must be apportioned. Specifically, they say the MRT isn’t a tax on “income,” as interpreted under the Sixteenth Amendment. The essence of this argument is that the plaintiffs, as shareholders of a controlled foreign corporation, haven’t “realized” any income but instead are being taxed on the value of their shares as measured by that corporation’s retained earnings—a direct tax on property. Read the full article here.