International Private Client Issues for Non-U.S. Residents: Serving High Net Worth Foreign Individuals and Families

Advisers to high-net-worth individuals are increasingly tasked with creating integrated solutions for their clients in all aspects of their lives. For non-U.S. based individuals, it is critical to have a U.S. advisor to coordinate cross-border issues involving U.S.-sitused businesses, investments, and trusts.

The United States is seen as a tax, privacy, and asset protection "haven" for high net worth foreign individuals. This creates an opportunity for advisors to provide critical wealth and trust planning as an element of a multi-discipline PCS practice.

Among the critical skills that a private client advisor must have is understanding possible immigration strategies, the tax, asset protection, and privacy of trusts, and deciding whether those trusts should be domestic or foreign and, if domestic, proper U.S. trust situs jurisdiction.

Listen as our experienced panel provides a thorough guide to the critical skills and practices of serving high net worth individuals and families through a PCS practice.

1. Components of a PCS practice serving non-U.S. high net worth individuals and families
2. Working with family offices
3. Trust structures for non-U.S. individuals with presence in the United States
4. Multi-jurisdictional tax planning strategies

The panel will review these and other important issues:

• Critical considerations in wealth preservation before a foreign individual becomes a U.S. resident for tax purposes
• Avoiding anti-deferral rules in pre-immigration transactions
• Determining whether a drop-off trust should be structured as a domestic or a foreign trust under the rules of Section 7701
• Helping non-U.S. taxpayers identify the optimal framework and structure for a family office to handle U.S.-sitused assets
• Comparing “top tier” U.S. jurisdictions with regard to tax, asset protection, and privacy planning

Learning Objectives

After completing this course, you will be able to:

• Determine the various ways nonresidents are taxed.

• Distinguish between ECI and FDAP.

• Identify situs considerations when forming trusts.

• Differentiate fixed, determinable, annual and periodic (FDAP) income from effectively connected income (EIC).

• Ascertain critical considerations in wealth preservation for foreign individuals.

• Recognize the advantages of a directed trust.

• 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 at mid-level within the organization, supervising other preparers/accountants, preparing complex corporate tax forms and schedules. Specific knowledge of rules governing corporate entity structuring, and federal income tax treatment of business entities. Familiarity with Subpart F rules and concepts of cross-border tax arbitrage and hybrid entities.

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).