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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

    Monday, April 29, 2024

  • 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.

$297.00
CLE
CPE
ALL

This CLE/CPE course will provide estate planners and tax professionals guidance on navigating the tax rules applicable to gifts from nonresidents and offer planning techniques to minimize adverse tax consequences and reporting mishaps. The panel will focus on (1) the tax aspects of gifts of U.S. assets by nonresident aliens, and (2) U.S. estate tax consequences of a nonresident alien dying with U.S. assets in his portfolio. The panel also will outline and analyze hypothetical gift and estate planning scenarios and offer effective planning techniques for estate planners and tax counsel.

Faculty

Burgess Raby
Principal
Raby Law Office

Mr. Raby's practice focuses on international tax matters, including planning for foreign investment into the United States, planning for United States persons investing and undertaking businesses outside the United States, ownership of foreign real estate by United States persons (FIRPTA), and ensuring that all United States reporting requirements are met, including FATCA, FBARs, and various IRS information returns. He also includes advising start-up companies and tax litigation matters, both international and domestic.

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Pallav Acharya
Founder and Owner
CPA Global Tax & Accounting, PLLC

Mr. Acharya provides tax and accounting services, specializing in international tax and business issues for nearly 3 decades. He advises his clients on cross border tax matters, providing services to multinational clients engaged in US inbound or outbound activities. His services include planning, structuring, consulting, compliance and transfer pricing issues. He has worked extensively in the area of IRS overseas voluntary disclosure initiatives and helped clients comply with international tax requirements. He has a wealth of experience in cross border tax planning and compliance issues related to outbound and inbound US businesses as well as non-resident and expatriate individuals.

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Description

Nonresident aliens who own property in the U.S. are subject to various U.S. estate and gift tax rules. Trusts and estates counsel must have a clear understanding of those rules' potential tax implications for nonresident gifts and devisees, so counsel can implement appropriate planning methods to avoid unintended tax consequences.

Generally, nonresident donors or their estates are taxed only on the value of their U.S. situs assets, including real and tangible personal property, business assets, and stock of U.S. corporations. As for gift taxes, nonresidents are subject to U.S. gift tax only on transfers of tangible personal and real property located in the U.S. and real property located in the U.S.

Listen as our panel discusses issues for trusts and estates counsel for gifts of U.S. assets by nonresident aliens, focusing on relevant tax rules and potential estate planning pitfalls and opportunities. The panel will also outline and analyze hypothetical estate planning scenarios and offer effective planning techniques for counsel.

Outline

  1. Domicile for estate and gift tax purposes
  2. Estate, gift, and generation-skipping transfer tax rules applicable to NRAs
  3. Pitfalls to avoid for NRA gifts under U.S. tax law
  4. Potential opportunities
    1. Gifts/bequests by nonresident aliens
    2. Dynasty trusts
    3. Reporting issues for U.S. recipients

  5. Best practices for estate planners and tax counsel

Benefits

The panel will review these and other key issues:

  • What are the key considerations in determining domicile for estate and gift tax purposes?
  • What estate, gift, and generation-skipping transfer tax rules apply to nonresident aliens?
  • What gift and bequest opportunities are available from nonresident aliens to U.S. citizens?
  • What reporting issues should counsel be cognizant of when U.S. persons receive gifts and bequests from nonresident aliens?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand key considerations in determining domicile for estate and gift tax purposes
  • Recognize what estate, gift, and generation-skipping transfer tax rules apply to nonresident aliens
  • Ascertain what gift and bequest opportunities are available from nonresident aliens to U.S. citizens
  • Identify what reporting issues should counsel be cognizant of when U.S. persons receive gifts and bequests from nonresident aliens

  • 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 pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

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.