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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Tuesday, February 27, 2024

  • 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.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00
CLE
CPE
ALL

This CLE/CPE webinar will provide estate planners, tax counsel, and advisers a detailed analysis of the application of U.S. estate tax to non-U.S. citizens receiving equity awards from or that hold shares in U.S. companies. The panel will focus on navigating potential estate tax implications for non-U.S. citizens, relevant tax rules and potential estate planning pitfalls, situs of assets, and the application of tax treaties.

Faculty

Jennifer J. McCall
Partner
Pillsbury Winthrop Shaw Pittman LLP

Ms. McCall chairs the Estates, Trusts & Tax Planning practice and is a leading authority on U.S. and international gift and estate planning. She crafts tax-savings business succession and estate transfer plans that preserve wealth and enhance family relationships. Her clients include internationally renowned museums and corporations, charities, foundations, high net worth families and individuals, fiduciaries and nonprofits. Ms. McCall's experience includes complex trust and estate administration and litigation; gift and generation-skipping transfer taxes; spousal rights of election and rights of adopted children; endowments; and tax aspects related to disposition of corporate holdings and financial transactions

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Mark C. Jones
Partner
Pillsbury Winthrop Shaw Pittman LLP

Mr. Jones provides strategic counsel to public and private corporations and senior executives on deferred compensation, stock awards, retirement benefits and severance pay. He has particular experience with international compensation and California blue sky laws. Mr. Jones frequently handles executive compensation and employee benefit issues that arise in M&As, spinoffs, IPOs and financings.

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Matthew Perotti
Counsel
Pillsbury Winthrop Shaw Pittman LLP

Mr. Perotti guides clients through sophisticated estate planning matters, leveraging use of clients’ tax exemptions to maximize transfer tax opportunities, and advises fiduciaries and beneficiaries on complex trust administration and litigation matters.

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Description

Non-U.S. employees or service providers receiving equity awards from U.S.-based companies or that hold shares in such companies may be subject to U.S. estate taxes. Estate planners and tax counsel must understand the nuances of the application of U.S. estate taxation to such individuals in order to properly assess their potential impact on estate and tax planning.

Non-U.S. citizens may be subject to U.S. estate tax rules unless an exemption or other tax relief applies under current U.S. tax law or an applicable tax treaty. A non-U.S. employee or service provider who dies holding equity or rights to profits of a U.S. company may subject their heirs to U.S. estate taxes and filings unless appropriate planning methods to avoid unintended tax consequences are implemented.

The application of U.S. estate tax laws to a non-U.S. citizen depends on domicile, situs of assets, and the application of a treaty. Non-U.S. citizens domiciled in the U.S. are provided the same exemption amount as U.S. citizens and may be subject to estate tax on their estate. Therefore, determining the domicile of a non-U.S. citizen is critical.

For those determined to be not domiciled in the U.S., the situs of their assets may be subject to U.S. estate taxes with limited exemption amounts. However, under such circumstances, an applicable estate tax treaty may mitigate any adverse tax consequences.

Trusts and estates counsel advising non-U.S. clients with or who plan on having equity awards or shares in U.S.-based companies must be aware of the rules that might impact their clients' U.S. estate tax liability attributable to such assets.

Listen as our panel discusses potential estate tax implications for non-U.S. citizens with equity awards or shares in U.S.-based companies, relevant tax rules and potential estate planning pitfalls, situs of assets, and the application of tax treaties

Outline

  1. Impact of equity awards and shares held by non-U.S. citizens
  2. Domicile
  3. Situs of assets
  4. Tax issues and application of tax treaties
  5. Planning strategies and pitfalls to avoid

Benefits

The panel will discuss these and other key issues:

  • How do non-U.S. citizens become subject to U.S. estate tax on their estate?
  • What are the key considerations in determining domicile for estate tax purposes?
  • Navigating equity awards and shares held in U.S.-based companies for non-U.S. employees or service providers
  • Key tax considerations for equity agreements with non-U.S. citizens
  • How does the situs of assets impact the application of estate tax rules?
  • What planning strategies are available when representing non-U.S. citizens with equity awards or who hold shares of U.S.-based companies?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify which estate and gift tax rules apply to non-U.S. citizens
  • Understand key tax reporting issues for U.S. and non-U.S. citizens who are recipients of gifts and bequests
  • Recognize how the tax rules and reporting apply to different estate planning scenarios involving non-U.S. citizens

  • 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, drafting wills and trust documents, supervising other attorneys or estate planners. Specific knowledge of concepts regarding taxation of foreign investments held by U.S. taxpayers and U.S. assets held by non-U.S. citizens; familiarity with tax treaty provisions.

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).