U.S. Estate and Gift Tax Treaties: Utilizing Specific Provisions to Mitigate Inheritance Taxes
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will review standard provisions in U.S. estate and gift tax treaties and explore specific provisions in treaties with particular countries that can be utilized to reduce or eliminate exposure to U.S. transfer taxes.
Outline
- U.S. estate and gift tax treaties: introduction
- Residency and domicile
- Special estate and gift tax treaty provisions
- Marital deduction
- Situs rules
- Charitable deductions
- Competent authority requests
- Disclosure of treaty-based return positions
- Specific provisions by country
- U.S.-Canada Income Tax Treaty
- United Kingdom
- Denmark
- Other countries
Benefits
The panel will cover these and other critical issues:
- How U.S. residency impacts inheritance taxes
- Filing competent authority requests to resolve treaty interpretation disputes
- Utilizing marital deductions for U.S. residents and nonresidents
- Disclosing treaty-based return positions
- Utilizing specific provisions in treaties to mitigate estate and gift taxes
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Kerrin N.T. Liu
Partner
Diosdi & Liu
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations,... | Read More
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court. Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.
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