A Guide to International Estate Planning for U.S. Citizens and Residents

(547 Ratings)

Produced on: October 03, 2017

Course Format On Demand Audio

Taught by


Course Description

Time 62 minutes
Difficulty Intermediate

Domestic estate planners more and more frequently encounter international fact patterns: non citizens who reside in or spend time in the United States or are considering moving here; U.S. persons who receive gifts from foreign persons, U.S. citizens living abroad or owning foreign assets; US citizens who marry citizens or residents of other countries. The U.S. tax and other laws in the cross-border area differ significantly from the domestic U.S. rules. This course will review basic concepts and frequently encountered fact patterns in international estate planning involving U.S. citizens and residents.

Learning Objectives:

  1. Discern the differences between a U.S. and a non-U.S. person and how they are taxed
  2. Discuss the tax and reporting requirements for U.S. persons who have foreign income, accounts, or assets
  3. Review the special estate and gift tax rules relating to the non-citizen spouse
  4. Consider planning ideas for foreign persons who want to benefit U.S. persons, purchase U.S. assets or move to the U.S.
  5. Explore what is involved in expatriation and how it is treated


Carl Merino

Day Pitney LLP

Carl Merino represents U.S. and non-U.S. families and companies on a wide range of personal and business tax matters, including cross-border income and estate tax planning, corporate and partnership tax issues, S corporations and income taxation of trusts and estates.

Carl works extensively in the international tax arena. He advises non-U.S. clients on structuring inbound investments to minimize federal and state income and estate tax exposure. He advises U.S. clients on tax aspects of foreign investments, including anti-deferral rules, entity classification issues and reporting requirements for foreign entities and trusts. His work in this area also encompasses pre-immigration and expatriation planning, tax issues of foreign trusts with U.S. beneficiaries, cross-border compensation and employment tax issues and corporate structuring for foreign companies setting up U.S. operations.

Carl is co-chair of the International Estate Planning Committee of the New York State Bar Association's Trusts and Estates Law Section. He frequently publishes articles on various aspects of cross-border tax planning.

G. Warren Whitaker

Day Pitney LLP

G. "Warren" Whitaker assists high net worth individuals and multinational families with complex domestic and international estate planning and related income tax, corporate and personal financial planning. Clients seek his experience with sophisticated international transactions; trust and estate issues, both domestic and international; family office needs; and trust services and fiduciary compliance. He is a former member of the firm's Executive Board.

Warren is a prolific writer and international speaker. Since 2003, he has been published or cited nearly 80 times in respected news sources, such as Bloomberg, The New York Times and Worth Magazine. He is the lead author of Private Clients Legal and Tax Planning, published by PLI in 2016, and co-authored the United States sections of Tottel's Succession Law and Bloomsbury's International Succession Laws.

He has also served in variety of leadership roles in his professional community, including serving as U.S. chair of the U.K.-based Society of Trusts and Estates Practitioners (STEP), member of the STEP Worldwide Council and chair of the Trusts and Estates Law Section of the New York State Bar Association, as well as the Section's International Estate Planning Committee and Estate Administration Committee and a former district representative.

Among his honors and recognitions is selection as a fellow of the prestigious American College of Trusts and Estates Counsel (ACTEC) and its International Estate Planning Committee.

For years, Warren's peers have named him to lists of top lawyers. As Chambers USA described him, "Warren Whitaker is the leading figure in the practice and is sought by clients for 'his depth of experience and intellect, and his very good grasp of cross-border taxation.'" Worth Magazine has named Warren as one of the nation's 100 Top Wealth Advisors. He also speaks French.


Henry V.

Great tips!


Excellent information and presentation. Thank you also for the written materials.

Katie T.

Presenters were excellent!

Chris T.

Excellent program

Catherine P.

Great speakers! Very knowledgeable and interesting topic. Would definitely recommend.

Eduardo L.

Very concise and informative

Nadia S.

Very well put together, answered a multitude of questions.

Lawrence C.

Extremely well done, thorough and comprehensive.

Mattie A.


John M.

Very knowledgeable

Whitney A.

very interesting

Mary C.

Excellent presentation

William K.

As a US citizen living in Canada I found this course to be very informative

Marty D.

Good clarification on who is an "ex-patriot."

lin l.

very good!

Damien R.

This presentation is one of the best CLE courses that I have seen. It contained an enormous amount of technical information, presented in a very easy to understand format. The presenters and course materials were fantastic!

Pamela W.

Interesting presentation of some complex issues.

Venola R.

Very complex. I still find it hard to believe that dual citizens could be taxed by the US on worldwide income. Seems a bit oppressive.

Barbara H.

Great job

Georgian P.

Very interesting information. Speakers were extremely thorough and helpful. Enjoyed the presentation!

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$ 59 Tax Law, International Law, and Wills, Trusts, & Estates In Stock


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