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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

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Conducted on Wednesday, October 5, 2022

Recorded event now available

or call 1-800-926-7926

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.


Advisers to high-net-worth individuals are increasingly 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. advisor to coordinate cross-border issues involving U.S.-sitused businesses, investments, and trusts.

The United States is seen as a tax, privacy, and asset protection "haven" for high net worth foreign individuals. This creates an opportunity for advisors to provide critical wealth and trust planning as an element of a multi-discipline PCS practice.

Among the critical skills that a private client advisor must have is understanding possible immigration strategies, the tax, asset protection, and privacy of trusts, and deciding whether those trusts should be domestic or foreign and, if domestic, proper U.S. trust situs jurisdiction.

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 PCS practice.



  1. Components of a PCS 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:

  • 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


Warren, David
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

McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.

Founder/Managing Partner
McCormick Tax

Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting...  |  Read More

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