Trust Distributions to Foreign Beneficiaries: Complex Planning and Calculation Challenges
Navigating the Interplay of Foreign Withholdings, Treaty Benefits, DNI Calculations, and Trust Compliance
A live 110-minute CPE webinar with interactive Q&A
This course will provide estate and trust tax advisers and compliance professionals with a thorough and practical guide to the tax compliance issues that fiduciaries face before making or allocating U.S. domestic trust or estate distributions to foreign beneficiaries. The panel will explain how to determine the U.S. status of foreign beneficiaries for U.S. tax purposes, detail how to calculate required withholding tax and net distribution amounts, discuss DNI implications of foreign beneficiaries, and explore the application of common tax treaty benefits.
Outline
- Classification and verification of residency status of beneficiaries
- Fiduciary accounting and DNI issues unique to domestic trusts with foreign beneficiaries
- Withholding requirements for domestic trust distributions to foreign beneficiaries
- Impact of tax treaty provision on domestic trusts with foreign beneficiaries
- Tax reporting requirements for domestic trusts and foreign beneficiaries
- Critical components of distribution planning and practice tips
Benefits
The panel will discuss these and other critical questions:
- Classification and verification of residency status of beneficiaries
- Fiduciary accounting and DNI issues unique to domestic trusts with foreign beneficiaries
- Withholding requirements for domestic trust distributions to foreign beneficiaries
- Impact of tax treaty provision on domestic trusts with foreign beneficiaries
- Tax reporting requirements for domestic trusts and foreign beneficiaries
- Critical components of distribution planning and practice tips
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.
CloseEarly Discount (through 10/10/25)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event.
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NASBA details.
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Early Discount (through 10/10/25)
CPE credit is not available on downloads.
CPE On-Demand
