Deciding and Converting Between Grantor and Nongrantor Trust Status: Evaluation of Planning Opportunities and Potential Pitfalls

Ms. Brittain is a private wealth services attorney in Holland & Knight's Century City and Newport Beach offices. She works closely with private clients in the U.S. and around the world, designing efficient strategies that maximize tax benefits for individuals and their companies while meeting personal wealth transfer and business succession needs. Ms. Brittain has decades of experience advising high-net-worth and ultra-high-net-worth individuals and families on domestic and international income and estate tax planning strategies and philanthropic endeavors. Her practice offers significant cross-border experience for families whose members are multinational and whose companies have a global footprint. Ms. Brittain helps clients navigate complex issues relevant to international and domestic wealth and asset transfers. She also assists with pre-immigration planning and international corporate tax matters, leveraging her extensive experience with the cross-border regulatory laws that affect planning and compliance. Ms. Brittain is frequently sought out by international private clients and their advisory teams in urgent, high-stakes situations to help mitigate legal and reputational risk.

Ms. Zhou focuses her practice on counseling high net worth individuals, trustees, and financial institutions on the US tax implications of wealth transfer strategies, with an emphasis on international income and estate tax planning. She has substantial experience advising clients on all aspects of FATCA and CRS as well as various withholding tax and disclosure regimes. Ms. Zhou frequently counsels clients on the US tax consequences of expatriation from and immigration to the United States, and of US inbound and outbound investment structures. She also advises on the creation, administration and governance of offshore trust structures.