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

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, May 30, 2019

Recorded event now available

or call 1-800-926-7926
Course Materials

This course 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.


Advisers to high net worth individuals increasingly are tasked with creating integrated solutions for their clients in all aspects of their lives. For non-U.S. based individuals, it is critical to have a U.S. adviser to coordinate cross-border issues involving U.S.-sitused businesses and investments.

The United States is seen as a tax haven for high net worth foreign individuals, even as U.S. corporations invert to lower-tax destinations. U.S. resistance to additional banking disclosure rules is reinforcing America's image as the ultimate destination for many wealthy foreign individuals. This creates an opportunity for tax advisers to provide critical income and transfer tax planning as an element of a multi-discipline private client service practice.

Among the critical skills a private client adviser must have is an understanding of possible immigration strategies, the tax impact of "drop-off trusts" and deciding whether those trusts should be domestic or foreign trusts. Crucial to any wealth transfer and tax minimization plan is an understanding of the new provisions of the 2017 tax reform law, and how a possible sunset of some favorable provisions may impact a cross-border/multi-jurisdictional strategy.

Listen as our experienced panel provides a thorough guide to the critical skills and practices of serving high net worth individuals and families through a private client services practice.



  1. Components of a private client services practice serving non-U.S. high net worth individuals and families
  2. Working with family offices
  3. Trust structures for non-U.S. individuals with presence in the United States
  4. 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


McCormick, Patrick
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

Warren, David
David A. Warren, JD

Co-Founder and Chairman of the Board
Bridgeford Trust Company

Mr. Warren is an attorney with over 15 years of professional experience practicing law and working in the financial...  |  Read More

Williams, Stephen
Stephen Williams, CPA

Business Advisory Partner
PW Associates

Mr. Williams provides seasoned business, financial and tax guidance to U.S. and internationally operated enterprises...  |  Read More

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CPE credit is not available on downloads.