BarbriSFCourseDetails
  • videocam Live Online with Live Q&A
  • calendar_month November 18, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Estate Planning
  • schedule 90 minutes

Structuring Trust-to-Trust Transfers to Address Deficiencies in Existing Irrevocable Trusts

Avoiding Transfer Tax Consequences, Navigating Fiduciary Issues and Notification Requirements

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$252.45
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Description

Estate planning attorneys and advisers frequently are confronted with existing irrevocable trusts whose provisions no longer meet the client's needs. Whether through change in family/beneficiary situations, changes in asset composition, defects in the original trust document, or different tax strategy requirements, planners must be able to modify these stale irrevocable trusts to ensure clients have a tax-efficient means of transferring assets to designated beneficiaries.

A critical tool for estate planning counsel is structuring trust-to-trust transfers to address deficiencies in these trusts. Estate planners can structure new or existing irrevocable trusts to serve as recipients of assets from these existing stale trusts, making sure the terms of the new trust meet the updated needs of their clients.

These trust-to-trust transactions are not without tax and fiduciary risks, so estate planners must be fully aware of potential transfer tax consequences, fiduciary impacts upon trustees, and various state law provisions that may complicate the transfers. Structuring the recipient trust to avoid these negative consequences is critical to achieving a tax-efficient asset result.

Listen as our experienced panel provides a practical guide to structuring trust-to-trust transfers as a means of fixing stale irrevocable trusts.

Presented By

Shudan Zhou
Partner
Norton Rose Fulbright, LLP

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.

Credit Information
  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, November 18, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. What makes a trust "stale"

II. Fiduciary concerns and risks

III. Transfer tax consequences and how to avoid them

IV. Planning and methods to deplete the stale/existing trust

The panel will discuss these and other important issues:

  • How to identify trust provisions that need repair or refreshing
  • State law provisions that hinder or facilitate the structuring of trust-to-trust transfers to remedy defects in existing trusts
  • Potential transfer tax consequences of structuring trust-to-trust transfer vehicles and how to avoid those consequences
  • Potential fiduciary concerns in trust-to-trust transfer transactions