Foreign Trust Transition Planning: Distributions to Beneficiaries, Trust Restructuring, Reporting Requirements
Grantor to Nongrantor Trust Tax Implications, DNI, Accumulation of Trust Income, Throwback Tax, Planning Techniques
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE webinar with Q&A
This CLE course will provide guidance to estate planners on overcoming the challenges of foreign trust transition planning. The panel will discuss complex tax rules and reporting obligations, the pros and cons of foreign grantor vs. nongrantor trusts, distributions to U.S. and foreign beneficiaries, trust restructuring, and other key considerations for estate planners.
- Overview of U.S. tax treatment of foreign trusts
- Trust transition planning options and challenges
- Distributions to U.S. beneficiaries
- Distributions to foreign beneficiaries
- Trust restructuring
- Best practices and common issues for estate planners and advisers
The panel will review these and other key issues:
- What are the pros and cons of foreign grantor vs. nongrantor trusts?
- What are the U.S. tax implications for foreign trusts with U.S. beneficiaries?
- What are the key considerations and options for trust restructuring to minimize the tax liability of foreign trusts?
- What are some planning techniques available to avoid adverse U.S. tax implications for transition of the foreign grantor to nongrantor trusts?
Jack R. Brister, TEP
International Wealth Tax Advisors
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset... | Read More
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include foreign trusts, estates and foundations that have a U.S. connection, as well as foreign companies wanting to do business in the U.S. He also specializes in foreign investment in U.S. real property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures, FATCA registration, executives working and living abroad and annual reporting. He has been widely published, in addition to speaking at numerous international engagements.Close
Jack C. Millhouse, CPA, JD
International Tax Senior Manager
Mr. Millhouse is a Senior Manager in FGMK’s Specialty Tax Practice. He is an attorney with over 10 years of... | Read More
Mr. Millhouse is a Senior Manager in FGMK’s Specialty Tax Practice. He is an attorney with over 10 years of experience in compliance, planning, reporting, and structuring services to corporations and partnerships in the domestic, foreign, taxable and tax-exempt sectors. Mr. Mr. Millhouse's industry experience includes manufacturing, pharmaceutical, private equity, and technology. He evaluates and recommends tax-efficient planning and investing options, facilitates partnership and corporate purchases, and provides guidance on restructuring and sales transactions.Close