International Private Client Issues for Non-U.S. Residents: Serving High Net Worth Foreign Individuals and Families
Foreign vs. Domestic Drop-Off Trusts, Working With Family Offices, Multi-Jurisdictional Income, and Wealth Transfer Tax Planning
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers with a practical guide to the planning opportunities and potential tax pitfalls involved in providing private client services (PCS) for high net worth nonresident clients with U.S. tax presence. The panel will go beyond the basics to detail intricate strategies for minimizing income tax, including basis strategies for non-U.S. situs assets, structuring "drop-off" trusts, and planning for the possibility of the nonresident alien's return to the country of origin.
- Components of a private client services practice serving non-U.S. high net worth individuals and families
- Working with family offices
- Trust structures for non-U.S. individuals with presence in the United States
- Multi-jurisdictional tax planning strategies
The panel will review these and other important issues:
- What are the key considerations in wealth preservation before a foreign individual becomes a U.S. resident for tax purposes?
- How to avoid anti-deferral rules in pre-immigration transactions
- Determining whether a "drop-off trust" should be structured as a domestic or a foreign trust under the rules of Section 7701
- Helping non-U.S. taxpayers identify the optimal framework and structure for a family office to handle U.S.-sitused assets
Patrick J. McCormick, J.D., LL.M.
Drucker & Scaccetti
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close
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