Description
With increasing high net worth clients acquiring citizenship or permanent residency in multiple countries, counsel and tax advisers should recognize estate planning issues. Counsel's initial inquiry establishes whether a new client is a U.S. income tax resident and a U.S. domiciliary.
Spouses and children may have different citizenships and residency statuses, which will also impact the estate plan. Many nonresident aliens have children/grandchildren who are U.S. income tax residents. There may be significant transfer tax advantages of gifts and bequests from nonresident aliens to U.S. persons.
Estate planning attorneys and tax advisers must also identify tax opportunities and risks for clients, understand the reporting issues that apply to the U.S. recipients of gifts, and anticipate problems that arise when non-U.S. individuals acquire or transfer U.S. assets.
Listen as our panel of estate planning attorneys experienced in international issues discusses the estate, gift, and generation-skipping transfer tax rules for resident and nonresident aliens. The panel will also outline basic planning scenarios and key potential trouble spots and opportunities.
Presented By
Ms. Kayan leads a collaborative team of professionals to address the cross border needs of high net-worth business connected individuals. Since 2010, she has been a key developer of EY Private's cross border team. Ms. Kayan focuses on teaming with EY affiliated firms and other subservice lines to offer exceptional global client service.
Mr. Levin’s practice includes federal, state and local taxation; estate planning, trusts and estates administration; charitable giving; and succession planning for closely held businesses.
Mr. Packman is an ACTEC Fellow and partner in Holland & Knight LLP’s Private Wealth Services Section where he leads the firm’s International Estate Planning Group. Mr. Packman’s practice includes advising high-net-worth private clients (whether U.S. or foreign) with tax, trusts and estates. This also includes pre-immigration planning and expatriation planning. He also helps clients come into compliance and resolve tax controversies.
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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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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time
- event
Tuesday, February 25, 2025
- schedule
1:00 p.m. ET./10:00 a.m. PT
- Estate, gift, and generation-skipping transfer tax rules
- U.S. residents
- Non-U.S. residents
- Effect of bilateral estate and gift tax treaties
- Sample estate planning scenarios
- U.S. legal permanent resident married to U.S. citizen
- Both spouses are U.S. legal permanent residents
- Nonresident alien married to U.S. citizen
- Nonresident alien with U.S. assets
- Potential trouble spots
- Choosing executors/trustees
- Children with different citizenships
- Covered expatriates
- Potential opportunities
- Gifts/bequests by nonresident aliens
- Dynasty trusts
- Reporting issues for U.S. recipients
The panel will review these and other key issues:
- What estate, gift, and generation-skipping transfer tax rules apply to resident and nonresident aliens?
- What gift and bequest opportunities are available for transfer by nonresident aliens to U.S. persons?
- What are the reporting issues for counsel when U.S. taxpayer clients are recipients of gifts and bequests from nonresident aliens?
Learning Objectives
After completing this course, you will be able to:
- Recognize key challenges of estate, gift, and generation-skipping transfer tax rules
- Ascertain when treaty provisions may trump income and transfer tax rules
- Determine when income may be effectively connected with the U.S.
- Decide appropriate holding structures for U.S. assets
- 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.
BARBRI 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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
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