Foreign Trust Reporting Rules and Distribution Planning for U.S. Beneficiaries
A live 90-minute CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will provide estate planners and tax counsel comprehensive guidance on the reporting rules for foreign trusts under U.S. tax law. The panel will discuss key provisions of the Internal Revenue Code applicable to foreign trusts, the reporting regime for U.S. taxpayers' ownership of foreign trust assets, gift and estate tax treatment, and reporting obligations of U.S. beneficiaries of foreign trusts and non-grantor trusts. The panel will provide an in-depth review of Form 3520 and discuss distribution planning for foreign trusts with U.S. beneficiaries.
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
- Foreign grantor trust vs. foreign non-grantor trust
- Obtaining a tax-free step-up in basis
- Applicability of foreign anti-deferral rules and methods to avoid them
Benefits
The panel will discuss these and other key issues:
- What are the filing requirements for the U.S. beneficiary of a foreign trust?
- Avoiding pitfalls of complex tax rules and reporting obligations
- Understanding residency rules and the use of domestication to benefit the estate
- What "reportable events" trigger a Form 3520 filing requirement?
- What is the overlap between Form 3520 and other foreign information reporting requirements?
- What are the penalties and relief provisions for failing to file necessary forms?
- Effective techniques to avoid foreign anti-deferral rules
- Best practices for counsel regarding the taxation of foreign trusts
Faculty
Lawrence M. Lipoff, CPA, TEP
Director
CohnReznick
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private... | Read More
With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.
Closeto be announced.
Cannot Attend December 12?
Early Discount (through 11/15/24)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.