U.S. Tax Treatment of Gifts and Inheritances From Nonresidents
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will focus on (a) the tax aspects of gifts of U.S. assets by nonresident aliens, and (b) U.S. estate tax consequences of a nonresident alien dying with U.S. assets in his portfolio. The panel will outline and analyze hypothetical gift and estate planning scenarios and offer effective planning techniques for counsel.
Outline
- Domicile for estate and gift tax purposes
- Estate, gift, and generation-skipping transfer tax rules applicable to NRAs
- Pitfalls to avoid for NRA gifts under U.S. tax law
- Potential opportunities
- Gifts/bequests by nonresident aliens
- Dynasty trusts
- Reporting issues for U.S. recipients
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Best practices for trusts and estates counsel
Benefits
The panel will review these and other key issues:
- What are the key considerations in determining domicile for estate and gift tax purposes?
- What estate, gift, and generation-skipping transfer tax rules apply to nonresident aliens?
- What gift and bequest opportunities are available from nonresident aliens to U.S. citizens?/li>
- What reporting issues should counsel be cognizant of when U.S. persons receive gifts and bequests from nonresident aliens?
Faculty

Burgess Raby
Principal
Raby Law Office
Mr. Raby's practice focuses on international tax matters, including planning for foreign investment into the United... | Read More
Mr. Raby's practice focuses on international tax matters, including planning for foreign investment into the United States, planning for United States persons investing and undertaking businesses outside the United States, ownership of foreign real estate by United States persons (FIRPTA), and ensuring that all United States reporting requirements are met, including FATCA, FBARs, and various IRS information returns. He also includes advising start-up companies and tax litigation matters, both international and domestic.
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Rufus Rhoades
International Tax Attorney
Rufus v. Rhoades
Mr. Rhoades provides tax consulting to law firms, accounting firms, and international trust companies. He specializes... | Read More
Mr. Rhoades provides tax consulting to law firms, accounting firms, and international trust companies. He specializes in international tax, foreign tax issues, nonresident issues, and provides expert testimony for international taxation matters. Mr. Rhoades is the Past Chairman of Los Angeles County Bar Association Section of Taxation, Foreign Tax Committee, and a past member of the Executive Committee Section on Real Estate & International Fiscal Association. In addition to his experience in tax law, he has also co-authored and co-edited guides and books regarding international tax law. Mr. Rhoades speaks at a variety of international taxation seminars and has been an adjunct professor of law at the University of San Diego, as well as the University of Southern California Law School.
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