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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Tuesday, June 15, 2021

  • 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.

$297.00
CLE
ALL

This CLE course will provide estate planners an in-depth analysis of available estate planning techniques for multinational families. The panel will discuss legal challenges, the impact of new U.S. tax law changes, 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.

Faculty

Andrew Bernknopf
Member
De Castro West Chodorow Mendler & Glickfeld, Inc

Mr. Bernknopf is a tax, business and estate planning lawyer who takes an integrated approach to his practice. His practice involves U.S. income, estate and gift tax and wealth transfer planning for U.S. and international families; executive relocation, pre-immigration and emigration tax planning; domestic, inbound and outbound U.S. structures for investments, real estate and business interests and transactions; planning involving U.S. and foreign grantor and non-grantor trusts; entertainment and technology industry issues; and corrective tax compliance and tax controversy representation.

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Elizabeth L. Morgan
Principal
Elizabeth Morgan & Associates

Ms. Morgan represents a wide array of clients faced with multi-jurisdictional tax, estate, and business planning issues. She is experienced in the design of complex estate and business plans for U.S., non-U.S., and dual-citizen clients, and in assisting such clients with their pre-immigration and expatriation tax planning. Ms. Morgan frequently advises clients on the resolution of international tax and treaty issues in connection with their estate and business planning and serves as outside counsel to several high net worth family offices.

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Description

Many U.S. citizens and permanent residents have non-U.S. spouses or family members or property interests abroad; likewise, many non-U.S. citizens/non-U.S. residents have property interests or U.S. family members. Under current U.S. tax law, estate planning can create some specific complications for multinational families. Estate planning counsel and tax advisers must be prepared to assist these clients in navigating the complicated tax and wealth planning rules associated with cross-border interests.

U.S. tax rules for estate, gift, and generation-skipping transfer taxes may offer gift planning opportunities. In contrast, some rules for the income taxation of corporations and partnerships may impact how investments are structured. Also, holding business and investment assets through foreign corporations may subject U.S. shareholders to additional tax liability.

Estate planning for international families must consider which countries' laws govern the disposition of assets, as well as the income, estate, and gift tax treatment of specific transactions, including the interaction of multiple tax regimes.

Listen as our experienced panel guides attendees on how to plan the estates of clients with interests in foreign business entities, real estate, and financial accounts. The panel will cover the legal and tax considerations when planning for the disposition of each type of asset and the implications of U.S. tax law.

Outline

  1. Implications of current U.S. tax law on international estate planning
  2. Estate planning tax and legal issues for business interests in the international context
    • Corporations
    • Debt instruments
    • Intangibles
    • Partnerships and LLCs
    • CFC rules
  3. Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
    • Gifts of money
    • Dynasty trusts
    • Foreign grantor trust rules
    • Non-grantor trust rules
    • Real estate

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 U.S. or foreign grantor or non-grantor trusts for cross-border estate planning, including potential uses of "dynasty" trusts