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 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.
Outline
- Implications of current U.S. tax law on international estate planning
- Estate planning tax and legal issues for business interests in the international context
- Corporations
- Debt instruments
- Intangibles
- Partnerships and LLCs
- CFC rules
- Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
- Gifts of money
- Dynasty trusts
- Foreign grantor trust rules
- Non-grantor trust rules
- Real estate
Benefits
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
Faculty
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
Mr. Bernknopf is a tax, business and estate planning lawyer who takes an integrated approach to his practice. His practice involves U.S. income, estate and gift tax and wealth transfer planning for U.S. and international families; executive relocation, pre-immigration and emigration tax planning; domestic, inbound and outbound U.S. structures for investments, real estate and business interests and transactions; planning involving U.S. and foreign grantor and non-grantor trusts; entertainment and technology industry issues; and corrective tax compliance and tax controversy representation.
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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
Ms. Morgan represents a wide array of clients faced with multi-jurisdictional tax, estate, and business planning issues. She is experienced in the design of complex estate and business plans for U.S., non-U.S., and dual-citizen clients, and in assisting such clients with their pre-immigration and expatriation tax planning. Ms. Morgan frequently advises clients on the resolution of international tax and treaty issues in connection with their estate and business planning and serves as outside counsel to several high net worth family offices.
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