Estate Planning With Foreign Trusts and U.S. Beneficiaries: Tax Issues, Residency, Foreign Anti-Deferral Rules
A live 90-minute CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will guide estate planners on overcoming the challenges of foreign trusts with U.S. beneficiaries in estate planning. The panel will discuss complex tax rules and reporting obligations, entity and residency classification rules, and qualifying nonresident alien (NRA) grantors as tax owners under Sections 671 and 679, achieving a step-up basis, and techniques to avoid foreign anti-deferral rules.
Outline
- Issues of foreign trusts with U.S. beneficiaries in estate planning
- Determining tax residency and applicable rules
- Understanding tax rules and reporting obligations of foreign trusts for U.S. estates and taxpayers
- Obtaining a tax-free step-up in basis
- Applicability of foreign anti-deferral rules and methods to avoid them
Benefits
The panel will review these and other key issues:
- Determining if an arrangement is classified as a trust
- Avoiding pitfalls of complex tax rules and reporting obligations
- Understanding residency rules and the use of domestication to benefit the estate
- Section 671 and qualifying NRA grantors as tax owners
- Section 679 rules on pre-immigration trusts
- Methods to achieve step-up in basis
- Effective techniques to avoid foreign anti-deferral rules
- Best practices for counsel in overcoming challenges of foreign trusts with U.S. beneficiaries
Faculty
Bruna Barbosa
Attorney
Mayer Brown
Ms. Barbosa advises global families with substantial international assets on strategies for minimizing US... | Read More
Ms. Barbosa advises global families with substantial international assets on strategies for minimizing US federal income and transfer taxation to maximize transfer of wealth to future generations. She has extensive knowledge on US federal tax issues related to US inbound and outbound investments, including leveraged investments in US real estate, investment in funds and private equity, restructuring and treaty benefits. Ms. Barbosa regularly advises on pre-immigration and mobility planning, asset protection, marital agreements, cross-border and cross-generational transfers of wealth, cross-border trust and estate administration as well as tax compliance and reporting.
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Burgess Raby
Principal
Raby Law Office
Mr. Raby's practice focuses on international tax matters, including planning for foreign investment into the United... | Read More
Mr. Raby's practice focuses on international tax matters, including planning for foreign investment into the United States, planning for United States persons investing and undertaking businesses outside the United States, ownership of foreign real estate by United States persons (FIRPTA), and ensuring that all United States reporting requirements are met, including FATCA, FBARs, and various IRS information returns. He also includes advising start-up companies and tax litigation matters, both international and domestic.
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Cannot Attend September 18?
Early Discount (through 08/22/25)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.
