Estate Planning With Foreign Trusts and U.S. Beneficiaries: Tax Issues, Residency, Foreign Anti-Deferral Rules
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will guide estate planners on overcoming the challenges of foreign trusts with U.S. beneficiaries in estate planning. The panel will discuss complex tax rules and reporting obligations, entity and residency classification rules, and qualifying nonresident alien (NRA) grantors as tax owners under Sections 671 and 679, achieving a step-up basis, and techniques to avoid foreign anti-deferral rules.
Outline
- Issues of foreign trusts with U.S. beneficiaries in estate planning
- Determining tax residency and applicable rules
- Understanding tax rules and reporting obligations of foreign trusts for U.S. estates and taxpayers
- Obtaining a tax-free step-up in basis
- Applicability of foreign anti-deferral rules and methods to avoid them
Benefits
The panel will review these and other key issues:
- Determining if an arrangement is classified as a trust
- Avoiding pitfalls of complex tax rules and reporting obligations
- Understanding residency rules and the use of domestication to benefit the estate
- Section 671 and qualifying NRA grantors as tax owners
- Section 679 rules on pre-immigration trusts
- Methods to achieve step-up in basis
- Effective techniques to avoid foreign anti-deferral rules
- Best practices for counsel in overcoming challenges of foreign trusts with U.S. beneficiaries
Faculty
Jack R. Brister, TEP
Managing Member
International Wealth Tax Advisors
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset... | Read More
Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include foreign trusts, estates and foundations that have a U.S. connection, as well as foreign companies wanting to do business in the U.S. He also specializes in foreign investment in U.S. real property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures, FATCA registration, executives working and living abroad and annual reporting. He has been widely published, in addition to speaking at numerous international engagements.
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Christopher J. Byrne, CPA
Attorney
Christopher J. Byrne
Mr. Byrne has been practicing in the field of international taxation and cross-border estate planning as a Certified... | Read More
Mr. Byrne has been practicing in the field of international taxation and cross-border estate planning as a Certified Public Accountant and as an Attorney at Law for over 25 years.
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