Description
Many non-U.S. citizens/non-U.S. residents have property interests or family members in the U.S. Under current U.S. tax law, estate planning can create some specific complications for multinational families with foreign trusts holding U.S. assets. Trusts and estates counsel must be prepared to assist these clients in navigating the complicated tax and wealth planning rules associated with non-U.S. structured trusts holding U.S. equities.
Estate, gift, and generation-skipping transfer tax rules may offer gift planning opportunities. Still, applicable tax rules for the income taxation of corporations and partnerships may impact how investments are structured. Holding U.S. business and investment assets through foreign trusts may trigger unintended tax liability.
For a non-U.S. settlor, effective planning for U.S. situs assets can protect the estate from U.S. estate tax and prove beneficial after the settlor's death for U.S. and non-U.S. beneficiaries. Trusts and estates counsel must take into account which countries' laws govern the disposition of assets, as well as the income, estate, and gift tax treatment of specific transactions, including the interaction of multiple tax regimes.
Listen as our experienced panel guides attendees on how to plan the estates of non-U.S. citizen/non-U.S. resident clients with interests in U.S. business entities, real estate, and financial accounts. The panel will cover the legal and tax considerations for non-U.S. trust structures holding U.S. assets under current U.S. tax law.
Presented By
Ms. Otero advises on a broad range of international tax and estate planning matters, working with both individuals and families with cross-border businesses and investments as well as corporate clients seeking to optimize their worldwide effective tax rate and to reduce foreign taxes through tax-efficient financing, efficient cash management, repatriation of earnings to the U.S. and transfer pricing analyses.
Ms. Yazedjian's practice focuses on estate and gift tax planning and individual and foreign income tax planning for multigenerational and multinational families and high net worth individuals. She has extensive experience counseling clients on their cross-border financial and personal interests involving the United States, both inbound and outbound. This can include business succession planning, acquisition or disposition of U.S. real estate, tax structuring prior to entering the United States, structuring the ownership of global assets and family wealth transfers between generations and advising on the U.S. income, estate and gift tax consequences particular to the ownership of U.S. and global assets. Ms. Yazedjian is often coordinating strategies with overseas counsel to develop structures that holistically address and manage a client's worldwide tax exposure and compliance.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Thursday, November 5, 2020
- schedule
1:00 p.m. ET./10:00 a.m. PT
- Tax rules impacting U.S. equities held by foreign trusts
- Succession planning challenges
- Issues regarding CFCs
- Advanced planning techniques
The panel will discuss these and other noteworthy issues:
- What are the challenges of foreign trust structures holding U.S. assets?
- What are the key tax provisions to consider?
- What trust provisions will ensure that trust assets receive a step-up in basis?
- What issues arise for foreign grantor trusts owning U.S. situs assets?
- What is the impact of the timing of the check-the-box elections upon the settlor's death?
- What are the implications of CFCs?
- What planning strategies are available to trusts and estate counsel?
