U.S. Estate and Gift Tax Treaties: Utilizing Specific Provisions to Mitigate Inheritance Taxes

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Wednesday, March 8, 2023

1:00pm-2:50pm EST, 10:00am-11:50am PST

Early Registration Discount Deadline, Friday, February 10, 2023

or call 1-800-926-7926

This webinar will review standard provisions in U.S. estate and gift tax treaties and explore specific provisions in treaties with particular countries that can be utilized to reduce or eliminate exposure to U.S. transfer taxes.

Description

An individual foreign investor's estate or donative transfer is subject to gift and estate tax at the same rates as U.S. residents. The current unified credit for foreigners, however, is only $60,000 compared to the $12.92 million (2023) exemption available to U.S. citizens and residents. U.S. residents often use the marital deduction to mitigate these extreme taxes; however, the rules for the marital deduction differ substantially for nonresidents. Whether or not an individual is a resident or domiciled in the U.S. significantly affects the impact of transfer taxes.

U.S. estate and gift tax treaties can be utilized to significantly reduce estate and gift tax exposure. The U.S. has estate or gift tax provisions in treaties with at least 15 countries, including Australia, France, Japan, and the United Kingdom. These treaties generally provide for more generous estate and gift tax exemptions and sometimes allow nonresidents to claim a marital credit. Understanding the ins and outs of general U.S. estate and gift tax treaty provisions and the U.S.' treaties with particular countries can reduce transfer tax liability for multinational taxpayers.

Listen as our panel of international tax attorneys explores common provisions in U.S. estate and gift tax treaties for estate and trust advisers.

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Outline

  1. U.S. estate and gift tax treaties: introduction
  2. Residency and domicile
  3. Special estate and gift tax treaty provisions
  4. Marital deduction
  5. Situs rules
  6. Charitable deductions
  7. Competent authority requests
  8. Disclosure of treaty-based return positions
  9. Specific provisions by country
    1. U.S.-Canada Income Tax Treaty
    2. United Kingdom
    3. Denmark
    4. Other countries

Benefits

The panel will cover these and other critical issues:

  • How U.S. residency impacts inheritance taxes
  • Filing competent authority requests to resolve treaty interpretation disputes
  • Utilizing marital deductions for U.S. residents and nonresidents
  • Disclosing treaty-based return positions
  • Utilizing specific provisions in treaties to mitigate estate and gift taxes

Faculty

Diosdi, Anthony
Anthony V. Diosdi

Partner
Diosdi Ching & Liu

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax...  |  Read More

Liu, Kerrin
Kerrin N. Liu

Partner
Diosdi Ching & Liu

Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations,...  |  Read More

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