Estate Planning for Resident and Nonresident Aliens

Navigating Estate, Gift, and GST Tax Rules; Leveraging Estate and Lifetime Gifting Opportunities

Note: CPE credit is not offered on this program

Recording of a 90-minute CLE video webinar with Q&A


Conducted on Tuesday, January 26, 2021

Recorded event now available

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Program Materials

This CLE webinar will focus on counsel and tax advisers' challenges in estate planning for resident and nonresident aliens, focusing on relevant tax rules and potential estate planning pitfalls and opportunities. The panel will outline and analyze hypothetical estate planning scenarios for both groups.

Description

With an increasing number of high net worth clients acquiring citizenship or permanent residency in multiple countries, counsel and tax advisers should recognize estate planning issues. Counsel's initial inquiry is to establish whether a new client is a U.S. income tax resident and a U.S. domiciliary.

Spouses and children may have different citizenships and residency status, which will also impact the estate plan. Many nonresident aliens have children/grandchildren who are U.S. income tax residents. There may be significant transfer tax advantages of gifts and bequests from nonresident aliens to U.S. persons.

Estate planning attorneys and tax advisers must also identify tax opportunities and risks for clients, understand the reporting issues that apply to the U.S. recipients of gifts, and anticipate issues that arise when non-U.S. individuals acquire or transfer U.S. assets.

Listen as our panel of estate planning attorneys experienced in international issues discusses the estate, gift, and generation-skipping transfer tax rules that apply to resident and nonresident aliens. The panel will also outline basic planning scenarios and key potential trouble spots and opportunities.

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Outline

  1. Estate, gift, and generation-skipping transfer tax rules
    1. U.S. residents
    2. Non-U.S. residents
    3. Effect of bilateral estate and gift tax treaties
  2. Sample estate planning scenarios
    1. U.S. legal permanent resident married to U.S. citizen
    2. Both spouses are U.S. legal permanent residents
    3. Nonresident alien married to U.S. citizen
    4. Nonresident alien with U.S. assets
  3. Potential trouble spots
    1. Choosing executors/trustees
    2. Children with different citizenships
    3. Covered expatriates
  4. Potential opportunities
    1. Gifts/bequests by nonresident aliens
    2. Dynasty trusts
    3. Reporting issues for U.S. recipients

Benefits

The panel will review these and other key issues:

  • What estate, gift, and generation-skipping transfer tax rules apply to resident and nonresident aliens?
  • What gift and bequest opportunities are available for transfer by nonresident aliens to U.S. persons?
  • What are the reporting issues for counsel when U.S. taxpayer clients are recipients of gifts and bequests from nonresident aliens?

Faculty

Kayan, Marianne
Marianne Kayan

Principal
Ernst & Young

Ms. Kayan leads a collaborative team of professionals to address the cross border needs of high net-worth business...  |  Read More

Levin, Jeffrey
Jeffrey S. Levin

Senior Partner
Squire Patton Boggs

Mr. Levin’s practice includes federal, state and local taxation; estate planning, trusts and estates...  |  Read More

Packman, Kevin
Kevin E. Packman

Partner
Holland & Knight

Mr. Packman is an ACTEC Fellow and partner in Holland & Knight LLP’s Private Wealth Services Section where he...  |  Read More

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