International Trust and Estate Planning: Key Issues Under Current U.S. Tax Law, Trust Structures, Reporting
Valuation Concepts, Tax Filings, Selecting Trust Jurisdiction, Trust Protectors, and Other Key Issues
A live 90-minute CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide estate planners an in-depth analysis of available estate planning techniques for families with citizenship, assets, or beneficiaries across multiple jurisdictions. The panel will discuss legal challenges, key issues under U.S. tax law, 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
- Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
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 utilizing certain trusts
Faculty
Sarah B. Jacobson
Partner
Day Pitney
Ms. Jacobson represents high net worth individuals and families in tax, estate planning and trust matters. Her practice... | Read More
Ms. Jacobson represents high net worth individuals and families in tax, estate planning and trust matters. Her practice is dedicated to assisting global families with some U.S. connection, including foreign families with U.S. beneficiaries and foreign individuals making U.S. investments. Ms. Jacobson devises creative strategies to facilitate tax-efficient wealth transfers among U.S. and foreign clients for their wealth worldwide. She has significant experience dealing with complex, international trust issues and routinely provides advice to U.S. beneficiaries and foreign fiduciaries on the related U.S. tax and compliance implications. Ms. Jacobson also assists foreign clients with respect to their inbound investments in U.S. real estate. She regularly implements foreign grantor trust structures, provides advice on foreign nongrantor trusts with U.S. beneficiaries, including those with significant undistributed net income (UNI) and passive foreign investment company (PFIC) issues, and assists with tax advantageous restructuring through trust domestication, migration and decanting. Ms. Jacobson has represented family offices and assisted clients with establishing private trust companies. She also advises clients with pre-residency planning before they relocate to the United States and U.S. clients with planning in advance of expatriation.
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Lawrence M. Lipoff, CPA, TEP, CEBS
Director
CohnReznick
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private... | Read More
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high net worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely-held businesses in the areas of income tax planning and compliance, estate planning and administration services, consultation regarding formation of family trusts and philanthropic structures. He is a frequent lecturer and author of articles published through professional forums on topics that include preparation of 1040/1041 & 706/709 returns, IRA/pension distribution, domestic and international asset protection, business succession, generation-skipping transfers, S corporation and fiduciary taxation including foreign trusts, alternative minimum tax, Chapter 14, family limited partnerships, international estate planning and administration, grantor charitable lead trusts, captive insurance companies, private placement life insurance and carried interest estate planning for private equity and hedge fund principals.
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Cannot Attend July 2?
Early Discount (through 06/07/24)
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.