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International Tax Issues Facing Domestic Estate Tax Planners


Product Code - TMW100
Speaker(s): Jim Brockway and Edward Vergara, 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 entity and account reporting (FBAR and FATCA implications)
  • Income taxation of US source income held by non US persons

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 Edward Vergara, Withers Bergman

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.

Edward Vergara is a partner with the Greenwich, CT office of Withers LLP and advises U.S. and multi-national individuals making domestic and international investment and succession planning decisions. Ed has extensive experience advising on U.S. inbound and outbound investments, individuals migrating into or out of the United States, U.S. beneficiaries of foreign trusts and foundations, and fiduciaries managing foreign structures for the benefit of U.S. persons. Ed also works with the principals of hedge funds and private equity funds on a variety of matters, including estate planning and advising on fund structures that satisfy investor demands while advancing important tax and estate planning goals of the principals.