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International Tax Issues for the Domestic Estate Planner


Product Code - TMW81
Speaker(s): Jim Brockway, and Todd Angkatavanich, Withers Bergman
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For many estate planners that focus primarily on domestic issues, international tax and legal issues are often ones that the practitioner would rather avoid. However, a number of international issues and potential pitfalls can arise unexpectedly in matters that the planner might otherwise consider to be purely "domestic."

This 90 minute presentation is designed to very broadly highlight the numerous international issues that the domestic estate planner should be aware of when dealing with client matters that may have some international implications. Topics to be discussed include:

  • Basic transfer and income tax rules for Non-US persons.
  • Relief under bilateral treaties
  • Transfers to Non-US citizen spouses
  • Foreign Trusts and implications with Grantor and Non-Grantor status
  • Controlled Foreign Corporations and Passive Foreign Investment Companies
  • Income tax basis issues
  • Pre-Immigration Planning
  • Expatriation planning
  • Foreign account reporting (FBAR and FATCA implications)
  • Income taxation of US source income held by foreign trusts and estates

Educational Objectives

With the increasing globalization of investments and families, it is clear that practitioners even if confining their practices to "domestic" issues will come across situations that require consideration of foreign persons or properties.

Attendees will:

  • Gain a "big picture" overview of the US international estate and income tax implications associated with estate and trust planning, and associated matters of administration
  • Understand the tax issues relating to Non-US properties and Non-US persons
  • Develop a broad understanding of income tax implications that can arise with respect to US persons holding interests in non-US entities and/or accounts and the compliance requirements in connection with same.

Who Should Attend?

  • Private estate planning attorneys
  • Accountants focused on "domestic" wealth transfer planning matters (but with some international aspects dealing with transferors, beneficiaries or properties)
  • Family Law practitioners
  • Real Estate attorneys

Prerequisite: None
Level: Intermediate to Advanced
Delivery method: Group InteractiveLlive
Recommended CPE credit: 1.5 credits 

Jim Brockway, and Todd Angkatavanich, Withers Bergman

Todd Angkatavanich is a partner with the law firm of Withers Bergman, where he focuses on tax, trusts and estates, and business succession matters for affluent individuals and their families. He regularly advises domestic and international families and family offices with respect to creating trust and related business structures to preserve, protect and grow family wealth for multiple generations in a tax efficient manner.

Todd has significant experience working with clients to structure US and international wealth preservation vehicles such as Family Limited Partnerships, Grantor Retained Annuity Trusts, Sales to Intentionally "Defective" Grantor Trusts, Foreign Grantor Trusts, Qualified Personal Residence Trusts, Buy-Sell Agreements and Preferred Freeze Partnerships. He also advises clients on business succession matters, with a particular emphasis on navigating the various tax pitfalls under Chapter 14 of the Code. In addition, Todd's practice also involves the preparation of estate planning documents for clients including "tax-sensitive" Wills and Revocable Trusts, Generation-Skipping
Dynasty Trusts and Irrevocable Life Insurance Trusts. Todd also has experience in advising Hedge Fund and Private Equity Fund professionals with respect to transferring carried interests into multi-generational trusts for the benefit of younger family members in a tax-efficient manner.

Todd is a frequent contributor to Trusts and Estates and Private Wealth magazines. He has also been published in Estate Planning magazine, ACTEC Journal, BNA Tax Management, Private Asset Management and other publications. He is a member of the Editorial Board for Trusts & Estates Magazine. He is also a member of the Advisory Board for BNA/Tax Management Estates, Gifts and Trusts.

Jim Brockway is co-chairman of the worldwide Wealth Planning practice group at Withers Bergman. His practice is global in scope with particular emphasis on offshore trust planning, planning for non-U.S. individuals and foreign assets, family investment and business planning, family offices and inbound and outbound business and income and transfer tax planning.

He also advises on corporate and partnership tax planning for closely held businesses, investment entities and funds management entities as well as on mergers and acquisitions and insurance and derivatives investment tax planning.