Gift and Estate Tax Planning for Foreign Assets: Reporting Requirements, Strategies for Tax Counsel and Estate Planners
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel and estate planners with a practical guide to navigating foreign assets in estate and tax planning and available techniques. The panel will discuss U.S. tax law as applied to foreign assets for estate planning purposes and go beyond the basics to detail intricate strategies for minimizing gift and estate taxes and pitfalls to avoid in handling foreign assets in estate planning.
Outline
- Taxes, income, estate and gift
- Non-U.S. Grantor with U.S. beneficiaries
- Solutions for NRAs owning assets in the U.S. such as real estate in the U.S.
- Tax treaties
- Pre-immigration considerations
- Outbound Grantor Trust Structures – various jurisdictions
- International Business Companies – Check the Box Elections for non US assets owned by NRAs
- International Banking - KYC
- Recognition of Applicable Tax Compliance Forms
- Review Forms 3520-A, 3520, 8938, 8858, FinCen 114 (FBAR), 5471 & 5472
Benefits
The panel will discuss these and other critical issues:
- Estate and gift tax planning techniques available under current tax law
- Key strategies for U.S. situs assets
- Key considerations in utilizing and structuring trusts
- Identifying willful and non-willful FBAR violations
- Uncovering reportable foreign assets held by trusts and estates
- Preparing Forms 3520 and 3520-A for foreign gifts and distributions received
Faculty
Ruben Gotlieb
Partner
Greenspoon Marder
Mr. Gotlieb is a partner with Greenspoon Marder’s International Wealth and Asset Planning and Wills, Trusts &... | Read More
Mr. Gotlieb is a partner with Greenspoon Marder’s International Wealth and Asset Planning and Wills, Trusts & Estates practice groups. With over 30 years of experience, he concentrates his practice on international estate planning, international estate tax law, domestic estate planning, estate administration, and pre-immigration tax planning. Mr. Gotlieb also regularly advises clients on cross-border matters, including the new GILTI and FDII provisions of the 2017 Tax Act.
CloseCarl Linder
Partner
Greenspoon Marder
Mr. Linder is a partner and Co-Chair of the International Wealth and Asset Planning Group at Greenspoon Marder. He has... | Read More
Mr. Linder is a partner and Co-Chair of the International Wealth and Asset Planning Group at Greenspoon Marder. He has advised individual, family office and business clients regarding global and domestic estate and gift taxes, corporate taxes, international taxes and state and local taxes. Mr. Linder works closely with financial institutions and other service providers in but not limited to New Zealand, Switzerland, Luxembourg, Andorra, Bahamas, Nevis, Cayman Islands, St. Lucia, and Anguilla. Additionally, he focuses on international trust planning primarily in the jurisdictions of the Cook Islands and Belize. Mr. Linder has used his knowledge to plan for inbound and outbound transfers of property, foreign entity structures including controlled foreign corporations and other international business companies, treaty based positions, real property transfers, investment tax credits and enterprise incentive programs (such as OZ Funds), personal income tax and tax related compliance issues. He has facilitated negotiations with federal and state tax authorities. Mr. Linder also drafts wills, trust agreements (domestic and international asset protection trusts, life insurance trusts, revocable and irrevocable Trusts), family limited partnerships and LLC’s and all other estate planning documents including health care directives and durable powers of attorney. He further advises clients on tax advantaged jurisdictions such as the Puerto Rico Act 60 program and the United States Virgin Islands Economic Development Commission (USVI EDC) program.
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