- videocam Live Online with Live Q&A
- calendar_month December 17, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
- signal_cellular_alt Intermediate
- card_travel Estate Planning
- schedule 90 minutes
Estate Planning for Multinational Families: Impact of OBBBA, Key Issues for Counsel
Transfer Tax Planning, Foreign Interests, Investments, and Unreported Income or Accounts
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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 and changes stemming from OBBBA, 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 impact of the OBBBA, 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. Erskine specializes in providing legal and fiduciary services for families, estates and businesses with unique assets or issues. He is client-focused, ensuring holistic financial security while preserving the ownership of a unique – but often illiquid – asset for the client and the family.
Ms. Regal is the Chief Executive Officer at Avrio Wealth Pte Ltd. She specializes in working with clients who have US tax connections. Ms. Regal is one of the only fee-based American wealth planners in Singapore. She employs an integrated, consultative approach to assist her clients in all areas of wealth planning including Investments, Tax, Insurance, Retirement, Estate Planning, Immigration or Expatriation from the United States. Prior to moving to Singapore with her family in 2007, Ms. Regal worked at Legg Mason Investment Counsel (LMIC), and its predecessors, providing highly tailored investment and trust strategies for affluent individuals, families and institutions. Before LMIC, she worked at Goldman Sachs.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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Live Online
On Demand
Date + Time
- event
Wednesday, December 17, 2025
- schedule
1:00 p.m. ET./10:00 a.m. PT
Outline
I. Implications of OBBBA and U.S. tax law 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
Benefits
The panel will review these and other key issues:
- Key planning considerations in light of OBBBA
- 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
Unlimited access to premium CLE courses:
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Unlimited access to premium CPE courses.:
- Annual access
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Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
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Unlimited access to Professional Skills and Practice-Ready courses:
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