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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, December 18, 2025

  • schedule Time

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

  • timer Program Length

    110 minutes

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).

Early Bird Pricing!
MSRP
$197.00
$167.45
Save $29.55

Discount expires 10/17/25

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CPE
ALL

This webinar will compare and contrast the U.S. estate planning principles with those of other countries for nonresidents and multinational taxpayers. Our panel of astute international wealth transfer advisers will discuss how inheritance rules differ between civil law and common law countries, as well as foreign estate and bequest information reporting requirements. They will also provide estate planning strategies for conveying assets and avoiding penalties for global taxpayers.

Faculty

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 is a Principal of The Wolf Group and oversees the firm’s international tax services in the areas of Offshore Voluntary Disclosure, US Exit Tax, foreign grantor and non-grantor trusts, nonresident alien taxation, international organization employee taxation, pre-immigration tax planning, and cryptocurrency. He assists individuals and businesses with highly specialized and complex tax issues related to offshore corporations, family businesses, trusts, and retirement plans. As a former attorney with the IRS Chief Counsel, Mr. Santa is well-positioned to guide clients on a range of reporting and disclosure issues. In addition, he speaks regularly at professional events sponsored by attorney and CPA groups in the US and abroad.

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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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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. 


Outline

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

Benefits

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

NASBA Details

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.


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.

IRS Approved Provider

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