Minimizing International Transfer Taxes: Utilizing Trusts, U.S. Estate and Gift Tax Treaties

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Thursday, May 16, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
-
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This webinar will outline methods to reduce gift, estate, and transfer taxes paid by taxpayers holding assets in the U.S. and abroad. Our panel of international trust and estate veterans will divulge planning techniques to minimize transfer taxes paid and point out caveats to avoid when formulating international estate plans for multinational taxpayers.
Faculty

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.

Ms. Skyberg has more than 14 years of public accounting experience providing services to a variety of clients. She specializes in international and domestic fiduciary, gift and estate taxation and provides corporate, partnership and individual taxation services. Ms. Skyberg assists with compliance, consulting and planning services for a variety of nonprofit organizations and private foundations.
Description
The lifetime estate and gift tax exemption is now $13.61 million for U.S. citizens and residents. For nonresidents, there is a $60,000 lifetime exemption. This remarkable difference is only one of the paramount reasons that foreigners holding U.S. assets or planning to live in the U.S. short or long-term need to prepare for international transfer taxes.
Numerous planning techniques can offer substantial transfer tax savings in the U.S. and abroad. A U.S. citizen married to a noncitizen may want to consider a QDOT (qualified domestic trust) or gifting assets up to the annual allowed exclusion of $185,000 (2024). The U.S. has estate tax treaties with 15 countries. These treaties can alleviate international taxes, or the double taxation, on the transfer of assets. Trust and estate advisers working with multinational taxpayers need to understand the latest planning techniques to minimize overall estate taxes paid by these individuals.
Listen as our panel of experienced international wealth professionals explains how to plan and prepare for transfer taxes in the U.S. and abroad.
Outline
- International trusts and estates: introduction
- U.S. transfer taxes
- Situs rules
- Utilizing trusts in international estate plans
- Treaty relief
- Required filings
Benefits
The panel will address these and other critical issues:
- Utilizing trusts, and caveats of utilizing trusts, in international estate tax planning
- Required filings that nonresidents could be subject to in the U.S.
- U.S. situs rules for taxing real property and intangibles
- How U.S. estate and gift tax treaties impact estate plans
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Decide how trusts can be used in international estate tax planning
- Ascertain how U.S. estate and gift tax treaties can lessen the burden of transfer taxes
- Identify caveats of utilizing trusts in estate planning for nonresidents
- 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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.

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