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Join us for this new, one-day beginner to intermediate seminar with live group instruction combining two aspects of U.S. taxation particularly relevant to cross border structures: Trusts and Passive Foreign Investment Companies (PFICs).
Trusts have long been favored vehicles for structuring investments and protecting assets. The classification of a foreign entity as a Passive Foreign Investment Company (“PFIC”) for U.S. tax purposes presents several significant issues for its U.S. shareholders.
A discussion of these two U.S. tax topics implicated in cross border investments should prove extremely worthwhile for individuals working with cross border structures. This seminar provides technical discussion regarding the background of these two topics, as well as planning for the challenges in these far reaching areas in today’s environment.
BENEFITS OF ATTENDING:
• Understand the main aspects of the U.S. Federal income taxation of trusts
• Explain the definitional issues associated with the federal tax classification of trusts
• Discuss the main attributes of foreign entities qualifying as Passive Foreign Investment Companies (PFICs) and the implications to U.S. investors
• Discuss the need for consideration of PFIC issues when structuring trusts with U.S. and non-U.S. parties
• Appreciate the overall Federal tax filing requirements associated with PFICs and trusts
• Discuss the potential PFIC implications and pitfalls stemming from recent events and developments
• And more!
WHY YOU SHOULD ATTEND
Bloomberg BNA has developed this new, one-day seminar discussing two significant tax topics impacting cross border structures and investments: 1) trusts and 2) Passive Foreign Investment Companies (“PFIC”).
Many cross border corporate structures as well as investment strategies for high net worth family investments often implicate PFIC issues. The applicability of the trust and PFIC rules is far reaching and the failure to stay abreast of their intricacies may be costly.
The complexity of these two areas and their far reaching impact cannot be overstated. The need for continued vigilance with regard to these issues is only increased by recent events.
WHO SHOULD ATTEND
This seminar is intended for accountants, tax advisers, attorneys and other financial executives looking to develop an understanding of how the US tax rules pertaining to trusts and PFICs intersect in the areas of cross border investment. No prerequisite is required for this introductory seminar with live group instruction. This program is transitional which is appropriate for newly admitted attorneys.
8:30 AM Registration and Continental Breakfast
9:00 AM Introduction and Chairpersons Opening Remarks
9:15 AM The “Trust” Essentials
• Definitional and classification issues, e.g. grantor trust, nongrantor trust, domestic vs. foreign
• Cross border scenarios, e.g. NRA grantor trust with US beneficiaries, Foreign non-grantor trust with NRA beneficiaries
• Overview – US filing requirements
10:30 AM Coffee Break
10:45 AM The Use of Trusts in Investment Structures
• Using trusts in estate and gift tax planning for high net worth families
• Implications of the “throwback” rules
• US tax issues for foreign trusts with US beneficiaries
12:15 PM Luncheon
1:00 PM PFIC Requisites
• PFIC Classification issues; e.g. the income and asset tests, the “look through” rules, consequences of excess distributions
• Applicability and consequences of elections, e.g. the “QEF” election, the “mark to market” election
• Overview – US filing requirements
2:45 PM Coffee Break
3:00 PM Trust Structures Implicating PFICs
• PFIC consequences of Investment structures involving trust entities
• Planning to avoid PFIC classification
4:00 PM Discussion of Current Issues Impacting PFICs and Trusts
• Increased applicability of PFIC classification issues
• IRS scrutiny of trust structures and the applicability of the PFIC regime
• Increased disclosure and compliance
5:00 PM Seminar Concludes
October 24, 2016
AMA Conference Center
1601 Broadway (at 48th and Broadway)
New York, NY 10019
Hotel accommodations are at your own discretion. We suggest the following:
319 West 48th Street
New York, NY 10036
Tel: (212) 245-7000
Novotel of New York
226 West 52nd Street
New York, NY 10019
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