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
Recording of a 110-minute CPE webinar with Q&A
This course will provide advisors with a practical guide to the planning opportunities and potential tax pitfalls 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 PCS 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:
- Critical considerations in wealth preservation before a foreign individual becomes a U.S. resident for tax purposes
- Avoiding 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
- Comparing “top tier” U.S. jurisdictions with regard to tax, asset protection, and privacy planning
David A. Warren, JD
Co-Founder and Chairman of the Board
Bridgeford Trust Company
Mr. Warren is an attorney with over 20 years of professional experience practicing law and working in the financial... | Read More
Mr. Warren is an attorney with over 20 years of professional experience practicing law and working in the financial services industry serving the trust and wealth management needs of high and ultra-high net worth families across the nation and around the world. Prior to establishing Bridgeford Trust Company, he was recruited out of a large and prestigious Mid-Atlantic law firm to join the Wealth Management/Trust Department of a regional bank as a Vice President/Senior Trust Administrator. Mr. Warren subsequently transitioned his career to Bank of New York Mellon where he worked exclusively and extensively with high and ultra high net worth families on various wealth management issues including asset protection and legacy planning.Close
Patrick J. McCormick, J.D., LL.M.
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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CPE credit is not available on downloads.