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2025 Tax Reform and Estate Planning for International Families

Impact of the One Big Beautiful Bill on Transfer Tax Planning, Foreign Interests, and Investments

A live 90-minute CLE/CPE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Thursday, October 16, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, September 19, 2025

or call 1-800-926-7926

This CLE/CPE webinar will provide estate planners with an in-depth analysis of available estate planning techniques for international families in light of the One Big Beautiful Bill Act (OBBB). The panel will discuss legal challenges; the impact of new U.S. tax law changes; transfer tax planning; and methods in managing foreign business interests, investments, and unreported income or accounts; and other complexities involved when a U.S. taxpayer has a foreign spouse or direct family member owning foreign or inbound-U.S. assets amid 2025 tax law changes.

Description

Many U.S. citizens and permanent residents have non-U.S. spouses or family members or property interests abroad; likewise, many non-U.S. citizens/non-U.S. residents have U.S. property interests or U.S. family members. Under current U.S. tax law, estate planning can create some specific complications for international families; however, more issues are presented by the OBBB.

U.S. tax rules for estate, gift, and generation-skipping transfer taxes may offer gift planning opportunities. In contrast, some rules for the income taxation of corporations and partnerships may impact how investments are structured. Also, holding business and investment assets through foreign corporations may subject U.S. shareholders to additional tax liability.

On May 22, 2025, the U.S. House of Representatives passed the OBBB, which includes extensions and expansions to the 2017 Tax Cuts and Jobs Act, as well as other provisions that impact estate and income tax planning.

Estate planning for international families must consider which countries' laws govern the disposition of assets, as well as the income, estate, and gift tax treatment of specific transactions, including the interaction of multiple tax regimes in light of pending U.S. tax reform.

Listen as our experienced panel guides attendees on how to plan the estates of clients with interests in foreign business entities, real estate, and financial accounts in light of pending U.S. tax reform. The panel will cover the legal and tax considerations when planning for the disposition of each type of asset and the implications of U.S. tax law.

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Outline

  1. Implications of the OBBB on international estate planning
  2. Estate planning tax and legal issues for business interests in the international context
    1. Corporations
    2. Debt instruments
    3. Intangibles
    4. Partnerships and LLCs
    5. CFC rules
  3. Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
    1. Gifts of money
    2. Dynasty trusts
    3. Foreign grantor trust rules
    4. Non-grantor trust rules
    5. Real estate

Benefits

The panel will review these and other key issues:

  • Impact of the OBBB on international estate and tax planning
  • Potential legal and tax pitfalls when planning for the disposition of a U.S. client's financial and real property interests abroad and a non-U.S. client's interests in the U.S.
  • The impact of situs rules on gifts and bequests by non-U.S. citizens/non-U.S. residents, including the disposition of interests in real property, business entities, and debt instruments, and issues involved in converting assets to "intangible" interests
  • U.S. tax reporting and compliance issues relating to the disposition of interests in business entities, real property, and financial accounts in the international context
  • Benefits and pitfalls of U.S. or foreign grantor or non-grantor trusts for cross-border estate planning, including potential uses of "dynasty" trusts

Faculty

Bakal, Scott
Scott J. Bakal

Shareholder
Greenberg Traurig

Mr. Bakal develops tax-planning strategies for closely held family businesses, partnerships, and publicly held...  |  Read More

Attend on October 16

Early Discount (through 09/19/25)

See NASBA details.

Cannot Attend October 16?

Early Discount (through 09/19/25)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video