Cross-Border Estate Planning After Tax Reform: New Opportunities and Obligations
Expanded Definitions of U.S. Shareholders, Deemed Repatriation for Trust Holdings, Restructuring Entities for Tax Minimization
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE program will provide estate planning counsel with a critical early look at the international implications of the new U.S. tax reform law on clients with cross-border assets and tax residence. The panel will offer guidance on examining and restructuring estate and trust documents for U.S. taxpayers to ensure that current wealth transfer plans conform with the provisions of the new law. The webinar will also address offshore business structures to determine whether a U.S. taxpayer with offshore holdings may achieve income tax benefits by restructuring those entities.
- Key provisions and changes impacting entrepreneurs and inbound investors
- Lower tax rates for corporations and individuals
- Pass-through income deduction
- Estate and gift tax exemption
- Impact on outbound activities of U.S. persons
- Participation exemption – limited territorial regime
- Deemed repatriation – transition toll tax
- Modifications of subpart F provisions
- Global intangible low tax income (GILTI)
- Impact on inbound activities of foreign persons
- Sale of partnership interest
- Foreign blocker corporations under new corporate tax rate
- New ESBT rules involving nonresident shareholders of S corporations
- Impact on offshore vehicles established for U.S. beneficiaries
- Changes to attribution of ownership rules
- Potential structures for tax and reporting minimization
The panel will review these and other key issues:
- How does the new tax law create the possibility for taxable “phantom income” for U.S. trusts with offshore assets?
- What impact will the permanent reduction in the U.S. corporate income tax rate have on non-U.S. persons and trusts holding U.S. real estate assets?
- What changes does the new law make to nonresident beneficiaries of ESBTs holding ownership interests in S corporations?
- How does the elimination of the “30-day rule” governing Controlled Foreign Corporation (CFC) status impact current and prospective estate planning structures?
Lucy S. Lee
Ms. Lee focuses her practice on international tax and estate planning for individuals and families. She represents high... | Read More
Ms. Lee focuses her practice on international tax and estate planning for individuals and families. She represents high net worth and global clients on a wide range of sophisticated matters, including inbound and outbound investments (including anti-deferral regimes and tax treaties), family wealth preservation, succession planning (including use of domestic and foreign trusts), tax compliance in the cross-border context, and pre-immigration tax and expatriation tax planning. She also advises funds and foreign financial institutions on U.S. tax and compliance (including FATCA), and represents taxpayers in administrative controversies with the IRS and in competent authority proceedings.Close
Lawrence M. Lipoff, CPA, TEP, CEBS
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private... | Read More
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high net worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely-held businesses in the areas of income tax planning and compliance, estate planning and administration services, consultation regarding formation of family trusts and philanthropic structures. He is a frequent lecturer and author of articles published through professional forums on topics that include preparation of 1040/1041 & 706/709 returns, IRA/pension distribution, domestic and international asset protection, business succession, generation-skipping transfers, S corporation and fiduciary taxation including foreign trusts, alternative minimum tax, Chapter 14, family limited partnerships, international estate planning and administration, grantor charitable lead trusts, captive insurance companies, private placement life insurance and carried interest estate planning for private equity and hedge fund principals.Close
Alvina H. Lo
Chief Wealth Strategist
Ms. Lo oversees the wealth planning, strategic advice and thought leadership services for the firm’s fast-growing... | Read More
Ms. Lo oversees the wealth planning, strategic advice and thought leadership services for the firm’s fast-growing Wealth Advisory division. She manages a national team of strategists, financial planners and thought leaders who advise high-net-worth individuals and families, business owners and entrepreneurs, and foundations and endowments. Previously, she served as the director and senior wealth planner for Citi Private Bank, and before that, she was a director at Credit Suisse. Earlier in her career, she practiced law at Milbank Tweed Hadley & McCloy, LLP in the Trust & Estates Group.Close