Withers Worldwide

Overview

Stephen’s practice encompasses international tax, domestic estate planning and planned charitable giving. International issues include pre-immigration planning, expatriation, trust taxation, UNI minimization strategies, foreign investment in US real estate and voluntary disclosures.  His estate planning practice entails pre-liquidity planning, dynasty trusts, grantor trusts, GRATs, family limited partnerships, and sophisticated insurance structures.  Stephen has extensive experience advising on the formation and operation of charitable remainder trusts, charitable lead trusts and private foundations, as well as the tax efficient donation of art.

Publications and speaking engagements

• Author of "In Estate of Duncan, the Tax Court Returns to Traditional Graegin Loan Principals," Journal of Taxation, April 2012.
• Author of "Foundations for Fund Principals," Private Wealth, March/April 2012.
• Author of "Owning US Real Estate: Depressed US Real Estate Yields a Rare Second Chance at Proper Structuring," Offshore Investment, October 2011.
• Author of "IRS Issues Draft Form 8938 Instructions," Trusts & Estates Wealth Watch, October 2011.
• Featured in Private Asset Management's "Ask the Experts" section, June 2011. 
• Co-author of "Changes to Connecticut's Estate and Gift Taxes," Withers Bergman LLP Briefing Notes, May 2011.  
• Author of "Oh my God!  You're an American!", STEP Journal, May 2011. 
• Author of "Coming Clean - The US Voluntary Disclosure Initiative in Perspective," Offshore Investment, April 2011. 
• Author of "Valuation Clauses: Panacea or Pandora's box?," Trusts & Estates Magazine, April 2011
• Author of "Maybe Price is Right: Making Annual Exclusion Gifts of Non-Controlling Interests," Practical Tax Strategies, July, 2010.
• Author of "Estate of Black: When is it ‘Necessary' to Pay Estate Taxes With Borrowed Funds?," Journal of Taxation, June, 2010.
• Presentation, "Tax and Reporting Obligations of US Green Card Holders," STEP Johannesburg, May 2010.
• Author of "HEART-ache: Expatriation Under the New Inheritance Tax," Estate Planning Journal, April 2010. 
• Author of "Efficient Gifting: Trusts and tax-advantaged accounts are powerful tools for gifting to children," Private Wealth, March/April 2010.
• Interview, "Building Broad Expertise," Leaders, Vol. 33, No. 1.
• Author of "Death of the Death Tax?" Withers Bergman LLP briefing note, December 2009. 
• Author of "Cross Border Philanthropy: Why is Doing the Right Thing Never Easy?", STEP U.S.A. Issue 10, November 2009.
• Author of "Giving to Greece: The Challenge of Cross-Border Philanthropy," Odyssey, May/June 2009.
• Author of "Fractional Interest Gifts of Art-Back to Stay or Going Away?" Taxation of Exempts, September/October 2008.
• Presentation on "Governance and Legal Framework for Private Social Investment" at the IDIS/CAF Foundation School, Sao Paulo, Brazil, October 2008.
• Presentation on "US Tax Planning Strategies for the International Family," August 2008.
• Author of "Striving for Certainty: How to use valuation clauses when transferring hard-to-value assets," Private Wealth, August 2008.
• Presentation on "The Tools and Techniques for Effective Business Succession Planning," February 2008. 
• Author of "Crossing the Generational Divide," Private Wealth, November 2007.
• Author of "Charitable Lead Annuity Trusts-A Primer," Taxation of Exempts, July/August 2007. 
• Presentation on "Estate Planning for Blended and Extened Families," at the 4th Annual Conference of the Association of Divorce Financial Planners, September 2006.
• Author of "Connecticut Estate and Gift Tax," Withers Bergman LLP briefing note, July 2005.
• Author of "Defining Trust Income," Trusts and Estates Magazine, May 2005.
• Presentation on "Installment Sales to Defective Trusts, Dispelling the Myths, Spelling Out the Opportunities," presented by Withers Bergman LLP, Connecticut, November and January 2004.
• Presentation on "How to Protect Assets During Life and Avoid Estate Tax at Death in Connecticut Use of Family Limited Partnerships in Estate Planning," sponsored by NBI, Inc., Connecticut, September 2003.

Memberships

• Connecticut Bar Association
• American Bar Association
• Society of Trust and Estate Practitioners

On a personal note

Stephen is an avid wine collector and conducts wine tastings in his free time.