Estate Planning Techniques for Multinational Families: Impact of U.S. Tax Law Changes, Planning Opportunities

Transfer Tax Planning, Foreign Interests, Investments, and Unreported Income or Accounts

Note: CPE credit is not offered on this program

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


Conducted on Tuesday, June 18, 2019

Recorded event now available

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Program Materials

This CLE webinar will provide estate planners, tax counsel and advisers an in-depth analysis of available estate planning techniques for multinational families. 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.

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 property interests or family members in the U.S. In light of new U.S. tax law changes, estate planning can create some specific complications for multinational families. Estate planning counsel and tax advisers must be prepared to assist these clients in navigating the complicated new tax and wealth planning rules associated with cross-border interests.

The Tax Cuts and Jobs Act of 2017 (TCJA) contains provisions that significantly change the international rules of the Internal Revenue Code. Changes to the estate, gift, and generation-skipping transfer taxes may offer gift planning opportunities while changes to 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.

Estate planning for international families must take into account 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.

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. The panel will cover the legal and tax considerations when planning for the disposition of each type of asset and the implications of the new U.S. tax law.

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Outline

  1. Implications of 2017 tax reform 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:

  • The impact of TCJA on estate, gift and income tax planning for multinational families
  • 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

Bernknopf, Andrew
Andrew Bernknopf

Member
De Castro West Chodorow Mendler & Glickfeld

Mr. Bernknopf is a tax, business and estate planning lawyer who takes an integrated approach to his...  |  Read More

Morgan, Elizabeth
Elizabeth L. Morgan

Principal
Elizabeth Morgan & Associates

Ms. Morgan represents a wide array of clients faced with multi-jurisdictional tax, estate, and business...  |  Read More

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