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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Tuesday, September 27, 2022

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00
CLE
CPE
ALL

This CLE course will provide trusts and estates attorneys with a practical guide to pre-immigration estate planning tools and techniques. The panel will go beyond the basics to detail intricate strategies for minimizing income tax, including basis strategies for non-U.S. situs assets, structuring "drop-off" trusts, and planning for the possibility of the nonresident alien's return to the country of origin.

Faculty

Anita W. Friedlander
Attorney
Martin & Associés

Mrs. Friedlander concentrates her practice in the areas of Tax Law both International & Domestic, Representation before the IRS, Including: IRS Audits, IRS Appeals, Collections & Tax Court Cases.

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Ronald A. Marini
Attorney
Martin & Associés

Mr. Marini is a Tax Attorney with more than 35 years of experience in the areas of Tax Law, both International & Domestic, including Representation before the IRS during IRS Audits, IRS Appeals, IRS Collections Actions & before the US Tax Court.

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Description

The U.S. imposes a tax on its residents' worldwide income requiring significant planning for would-be immigrants. Trusts and estates counsel must align planning strategies with current U.S. tax law for those seeking to become U.S. residents to avoid unintended tax liability for certain income and foreign assets.

Future immigrants must assess their financial situation and plan accordingly before becoming U.S. taxpayers in order to preserve their wealth. In some cases, for income tax purposes, it may be advantageous to accelerate income and gains and defer deductions/losses before establishing U.S. residency if, for example, the U.S. statutory tax rate is higher than the immigrant's current tax home. In other cases, the focus may be on sheltering worldwide assets from the U.S. tax system, especially if the person has or will inherit significant assets.

With thoughtful planning, clients may avoid unexpected aspects of U.S. tax law that could significantly impact family wealth. Estate planners must review clients' foreign companies and offshore mutual funds, consider the implications of foreign trusts, establish a gifting program, explore the use of insurance, and other methods of preserving wealth and minimizing income, estate, and gift taxes.

Listen as our panel discusses strategies for minimizing income, estate, and gift taxes, including basis strategies for non-U.S. situs assets, structuring "drop-off" trusts, and planning for the possibility of the nonresident alien's return to the country of origin.

Outline

  1. Residency and tax consequences
  2. Pre-immigration planning goals
  3. Income tax issues and planning
  4. Estate and gift tax planning
    1. Foreign assets and basis
    2. Use of trusts and other techniques
  5. Case studies and best practices for estate planners

Benefits

The panel will review these and other key issues:

  • What are the residency and tax consequences of immigrants coming to the U.S.?
  • What are the key pre-immigration estate planning considerations?
  • What are the income tax challenges and methods to minimize taxes?
  • What estate and gift tax planning techniques are available under current tax law?
  • What are the key basis strategies for non-U.S. situs assets?
  • What are the key considerations in utilizing and structuring trusts?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the residency and tax consequences of immigrants coming to the U.S.
  • Ascertain the critical pre-immigration estate planning considerations
  • Identify the income tax challenges and methods to minimize taxes
  • Ascertain estate and gift tax planning techniques available under current tax law
  • Recognize the key basis strategies for non-U.S. situs assets

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).