International Trust and Estate Planning: Key Issues Under Current U.S. Tax Law, Trust Structures, Reporting
Valuation Concepts, Tax Filings, Selecting Trust Jurisdiction, Trust Protectors, and Other Key Issues
Recording of a 90-minute CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide estate planners an in-depth analysis of available estate planning techniques for families with citizenship, assets, or beneficiaries across multiple jurisdictions. The panel will discuss legal challenges, key issues under U.S. tax law, transfer tax planning, and methods in managing foreign business interests, investments and unreported income or accounts, and other complexities involved when a U.S. taxpayer has a foreign spouse or direct family member owning foreign or inbound-U.S. assets.
Outline
- Implications of current U.S. tax law on international estate planning
- Estate planning tax and legal issues for business interests in the international context
- Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
Benefits
The panel will review these and other key issues:
- Potential legal and tax pitfalls when planning for the disposition of a U.S. client's financial and real property interests abroad and a non-U.S. client's interests in the U.S.
- The impact of situs rules on gifts and bequests by non-U.S. citizens/non-U.S. residents, including the disposition of interests in real property, business entities, and debt instruments, and issues involved in converting assets to "intangible" interests
- U.S. tax reporting and compliance issues relating to the disposition of interests in business entities, real property, and financial accounts in the international context
- Benefits and pitfalls of utilizing certain trusts
Faculty
Sarah B. Jacobson
Partner
Day Pitney
Ms. Jacobson represents high net worth individuals and families in tax, estate planning and trust matters. Her practice... | Read More
Ms. Jacobson represents high net worth individuals and families in tax, estate planning and trust matters. Her practice is dedicated to assisting global families with some U.S. connection, including foreign families with U.S. beneficiaries and foreign individuals making U.S. investments. Ms. Jacobson devises creative strategies to facilitate tax-efficient wealth transfers among U.S. and foreign clients for their wealth worldwide. She has significant experience dealing with complex, international trust issues and routinely provides advice to U.S. beneficiaries and foreign fiduciaries on the related U.S. tax and compliance implications. Ms. Jacobson also assists foreign clients with respect to their inbound investments in U.S. real estate. She regularly implements foreign grantor trust structures, provides advice on foreign nongrantor trusts with U.S. beneficiaries, including those with significant undistributed net income (UNI) and passive foreign investment company (PFIC) issues, and assists with tax advantageous restructuring through trust domestication, migration and decanting. Ms. Jacobson has represented family offices and assisted clients with establishing private trust companies. She also advises clients with pre-residency planning before they relocate to the United States and U.S. clients with planning in advance of expatriation.
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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.
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