Estate Planning Strategies for Noncitizen Residents
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Learn to identify and plan for common tax issues that arise when working with a multinational client.
Families and wealth are becoming increasingly international. More individuals work abroad, own property in more than one country, qualify as citizens or residents of multiple nations, and marry citizens of other nations than ever before. Each of these factors can subject individuals to the competing property, succession and tax laws of multiple jurisdictions. This topic will help you to identify and plan for common issues that can arise when dealing with a multinational client. Specifically, the program will address basic transfer tax issues for U.S. citizens, noncitizen residents and nonresident aliens; the treatment of foreign and domestic trusts; and estate planning issues concerning noncitizen spouses. Additionally, the program will cover special considerations for U.S. citizens living abroad; the U.S. expatriation rules; as well as traps for the unwary. Since the U.S. government places a heavy emphasis on enforcing its tax laws with respect to U.S. connected individuals, understanding the complexities of estate and tax planning for your international clients is of the utmost importance. This topic will provide you with the knowledge necessary to identify these key issues.
Speakers: Annette K. Eaton, Jay D. Rosenbaum
Course Content:
| Basis for Tax |
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- U.S. Citizens
- Noncitizen Residents
- Nonresident Aliens and Transfer Tax
- Trusts
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Noncitizen Spouse |
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- No Marital Deduction
- Special Annual Exclusion
- Qualified Domestic Trust
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U.S. Taxpayer Living or Owning Assets Abroad |
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- Treaty Considerations, Including New EU Succession Regulation
- Funded Trusts
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Problem Assets |
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- U.S. Beneficiary of Foreign Trust
- Receipts of Foreign Gifts and Bequests
- Foreign Bank Accounts and FBARS
- Controlled Foreign Corporations
- Passive Foreign Investment Company
- Other Compliance Considerations
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Expatriation |
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- Mark-To-Market Exit Tax
- Gifts and Bequests From Covered Expatriates
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