U.S. Real Estate and Other Private Use Assets Held by Non-Resident Aliens in the United States
Tax Rules, Succession Planning, CFCs, Alternatives
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE webinar with Q&A
This CLE course will provide trust and estate attorneys guidance on tax issues and planning techniques for non-U.S. trusts holding U.S. equities. The panel will discuss challenges of non-U.S. trust structures, critical tax provisions, succession planning, and implications of controlled foreign corporations (CFCs), as well as offer best practices and strategies for trusts and estate attorneys.
Outline
- Tax rules impacting U.S. equities held by foreign trusts
- Succession planning challenges
- Issues regarding CFCs
- Advanced planning techniques
Benefits
The panel will discuss these and other noteworthy issues:
- What are the challenges of foreign trust structures holding U.S. assets?
- What are the key tax provisions to consider?
- What trust provisions will ensure that trust assets receive a step-up in basis?
- What issues arise for foreign grantor trusts owning U.S. situs assets?
- What is the impact of the timing of the check-the-box elections upon the settlor's death?
- What are the implications of CFCs?
- What planning strategies are available to trusts and estate counsel?
Faculty
Maria-Soledad Otero
Partner
Karlin & Peebles
Ms. Otero advises on a broad range of international tax and estate planning matters, working with both individuals and... | Read More
Ms. Otero advises on a broad range of international tax and estate planning matters, working with both individuals and families with cross-border businesses and investments as well as corporate clients seeking to optimize their worldwide effective tax rate and to reduce foreign taxes through tax-efficient financing, efficient cash management, repatriation of earnings to the U.S. and transfer pricing analyses.
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Jeannette Yazedjian
Of Counsel
Karlin & Peebles
Ms. Yazedjian's practice focuses on estate and gift tax planning and individual and foreign income tax planning for... | Read More
Ms. Yazedjian's practice focuses on estate and gift tax planning and individual and foreign income tax planning for multigenerational and multinational families and high net worth individuals. She has extensive experience counseling clients on their cross-border financial and personal interests involving the United States, both inbound and outbound. This can include business succession planning, acquisition or disposition of U.S. real estate, tax structuring prior to entering the United States, structuring the ownership of global assets and family wealth transfers between generations and advising on the U.S. income, estate and gift tax consequences particular to the ownership of U.S. and global assets. Ms. Yazedjian is often coordinating strategies with overseas counsel to develop structures that holistically address and manage a client's worldwide tax exposure and compliance.
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