About the Course
Introduction
This CLE/CPE webinar will provide estate planners with an in-depth analysis of available estate planning techniques for international families in light of the One Big Beautiful Bill Act (OBBB). 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 amid 2025 tax law changes.
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 U.S. property interests or U.S. family members. Under current U.S. tax law, estate planning can create some specific complications for international families; however, more issues are presented by the OBBB.
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.
On May 22, 2025, the U.S. House of Representatives passed the OBBB, which includes extensions and expansions to the 2017 Tax Cuts and Jobs Act, as well as other provisions that impact estate and income tax planning.
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 in light of pending U.S. tax reform.
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 in light of pending U.S. tax reform. 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.
Presented By
Mr. Bakal develops tax-planning strategies for closely held family businesses, partnerships, and publicly held corporations with significant domestic and international operations. He works closely with high- and ultra-high-net-worth individuals and entrepreneurial companies to develop elegant, tax-sensitive approaches to their complex business transactions, financial situations, estate planning matters, and real estate investments, as well as to pursue tax efficiency throughout their operations. Mr. Bakal advises foreign individuals and families seeking to benefit from advantageous tax structures by migrating their investments and assets to the United States. He designs integrated strategies to encompass the complex components of both international and domestic tax planning. Mr. Bakal continuously monitors the tax planning landscape for new, compliant approaches that can be implemented with the goal of minimizing his clients’ liabilities to the full extent allowable under the law.
Ms. Rosenblatt focuses her practice on estate and tax planning for individuals and their families. She works closely with United States and non-United States citizens and residents and their advisors to create plans that achieve their goals while reducing potential conflicts and minimizing gift, estate, and income taxes. Ms. Rosenblatt also represents corporate and individual fiduciaries in connection with the administration of estates and trusts. Her practice encompasses a wide range of services, including estate, gift, and charitable planning, and multijurisdictional estate and tax planning. MS. Rosenblatt prepares wills, documents to address incapacity, revocable and irrevocable trusts, estate and gift tax returns, and premarital, marital, and cohabitation agreements. She also assists with business structuring and succession planning.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Wednesday, November 12, 2025
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. Implications of the OBBB on international estate planning
II. Estate planning tax and legal issues for business interests in the international context
A. Corporations
B. Debt instruments
C. Intangibles
D. Partnerships and LLCs
E. CFC rules
III. Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
A. Gifts of money
B. Dynasty trusts
C. Foreign grantor trust rules
D. Non-grantor trust rules
E. Real estate
The panel will review these and other key issues:
- Impact of the OBBB on international estate and tax planning
- 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
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