Tax Elections in Estate Planning for Non-U.S. Residents: Sec. 645 Elections, Entity Classification, Risks

Mr. Christopher assists successful U.S. and international individuals and their families in achieving their key tax and non-tax goals. His practice focuses on the tax and estate planning needs of U.S. and non-U.S tax payers. Mr. Christopher advises on all aspects of transfer tax planning and associated income tax planning for wealthy people, utilizing a variety of sophisticated techniques such as trust decanting, foreign grantor trusts, dynasty trusts and sales to intentionally defective grantor trusts, to create and to implement tax-efficient multi-generational wealth transfer structures. He has significant experience working with private equity and hedge fund professionals, as well as in the creation and on-going administration of family offices and the issues facing trustees in the administration of complex trusts.

Mr. Brister specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures which include foreign trusts, estates and foundations that have a U.S. connection, as well as foreign companies wanting to do business in the U.S. He also specializes in foreign investment in U.S. real property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures, FATCA registration, executives working and living abroad and annual reporting. He has been widely published, in addition to speaking at numerous international engagements.

Ms. Szabo is a founding member of CS CPA LLC. She is both an attorney and certified public accountant with a focus on international tax matters for both individuals and entities. Ms. Szabo has experience as an attorney and an accountant with international firms and has been a partner at major New York accounting firms. She is a published author with numerous articles featured in national publications as well as IRS Comment Letters regarding Proposed Regulations and IRS Notices. In addition to her law degree, Ms. Szabo has a Master of Laws in Taxation from Case Western Reserve School of Law, a Master’s of Accountancy from Cleveland State University and an APC in International Tax from NYU School of Law. She is barred as an attorney in New York, Connecticut, Pennsylvania, and Ohio and licensed as a certified public accountant in New York and in Ohio. Ms. Szabo is also barred and has litigated cases in U.S. Tax Court.