BarbriSFCourseDetails
  • videocam Live Online with Live Q&A
  • calendar_month December 18, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Tax Planning for Foreign Estates: Civil vs. Common Law Rules, Foreign Bequest and Estate Reporting, Wealth Transfers

$197.00

This course is $0 with these passes:

CPE
ALL
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Description

Estate planning for nonresidents and U.S. citizens with assets in other countries is problematic. While the One Big Beautiful Bill Act graciously extended the current, historically high exemption for federal estate and gift tax ($15 million per person in 2026), the prior, remarkably lower, nonresident exemption of $60,000 remains in place.

Further complications of foreign estate planning include differences between civil and common law systems among countries. Common law countries, such as the U.S. and the UK, recognize wills, the deceased's desires, and the executor's role in transferring assets. Notably more countries, including China and Spain, rely on civil law to transfer assets to beneficiaries. These countries have forced heirship rules that require the distribution of some or all assets to family members.

Further complicating transfer planning for international taxpayers is the inconsistent treatment by countries of common structures and trust arrangements. Additionally, the numerous U.S. reporting requirements for multinational taxpayers, accompanied by substantial penalties for noncompliance, make wealth transfer planning for foreign estates particularly complex. Global taxpayers and their advisers must recognize the caveats of multinational succession planning to facilitate a smooth transition of assets to heirs. 

Listen as our panel of foreign estate planning experts discusses caveats and considerations of foreign estate plans. 


Presented By

Frederic Behrens
Partner
Cerity Partners

Mr. Behrens is a Partner in the New York office, where he provides investment management and financial advisory services for high-net-worth individuals and international families. In particular, has significant experience working with U.S. citizens living abroad, nonresident aliens and mixed-nationality families. Well-informed on tax and compliance issues, Mr. Behrens brings significant cross-border tax and international estate planning expertise to his client relationships. Prior to joining Cerity Partners, he was a Partner, Wealth Advisor with Round Table Wealth Management. In this role, Mr. Behrens was responsible for managing clients and coordinating all aspects of the investment management and financial advisory services for his client relationships.

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Mishkin Santa
Principal, Director of International Tax
The Wolf Group, PC

Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift & trust tax compliance, FBAR Assistance, foreign trust tax compliance, exit tax planning, EB-5 investor program, international assignment structuring and planning, offshore voluntary disclosure programs, foreign corporation (Subpart F, Transfer Pricing, E&P Studies), and asset protection planning. His client base includes U.S. citizens living overseas, U.S. nonresidents, EB-5 investors, U.S. domestic individuals and families, international businesses, international based families with investments in multiple jurisdictions and tax residency in multiple jurisdictions, U.S. citizens or residents who are beneficiaries of foreign trusts and who will receive gifts or inheritances from non-US persons,  and trustees of trusts with U.S. grantors or U.S. beneficiaries.


 

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Beatrice Skyberg
Senior Manager
Eide Bailly

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.

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Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

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

Date + Time

  • event

    Thursday, December 18, 2025

  • schedule

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

I. U.S. estate tax general principles

II. Foreign estate: common law vs. civil law

III. Common foreign estate planning issues for U.S. persons

IV. Foreign flight of capital or capital control rules

V. Foreign Estate International Informational Reporting – IRC 6038D

VI. Foreign Bequest International Informational Reporting – IRC 6039F

VII. IRS Notice 97-34 

VIII. Forms 3520 (including Part IV) and 3520-A

IX. Foreign trusts: grantor vs. non-grantor

X. 2024 IRS proposed foreign trust regulations

XI. Migrating foreign trusts to U.S. trusts

XII. Potpourri structures: usufructs, private foundations, PPLI

XIII. IRS civil penalty and amnesty program solutions

The panel will cover these and other critical issues:

  • Common law vs. civil law rules for inheritance transfers
  • Required foreign estate and bequest information reporting in the U.S.
  • Migrating foreign trusts to U.S. trusts
  • Common foreign estate planning issues for U.S. persons

Learning Objectives

After completing this course, you will be able to:

  • Identify programs available to resolve international reporting noncompliance
  • Determine foreign bequest international reporting requirements
  • Decide how flight of capital rules impact asset transfers between countries
  • Ascertain how wealth transfers differ in civil vs. common law countries
  • 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.


BARBRI 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.

IRS Approved Provider

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

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .