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Estate Planning Techniques for Multinational Families: Key Issues Under Current U.S. Tax Law, 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 video webinar with Q&A

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

Conducted on Tuesday, June 15, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will provide estate planners 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.


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 U.S. family members. Under current U.S. tax law, 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 tax and wealth planning rules associated with cross-border interests.

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.

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.

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 U.S. tax law.



  1. Implications of current U.S. tax law 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


The panel will review these and other key issues:

  • 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


Bernknopf, Andrew
Andrew Bernknopf

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

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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