International Estate Planning After the Tax Cuts and Jobs Act

(144 Ratings)

Produced on: December 14, 2018

Course Format On Demand Audio

Taught by


Course Description

Time 60 minutes
Difficulty Intermediate

The Tax Cuts and Jobs Act introduced sweeping changes to the US tax rules, but perhaps few with as outsized an effect on estate planning structures as the changes surrounding US taxation of foreign income. While multinational companies were the primary target of many of the changes which were introduced, US citizen and resident owners of offshore companies and US citizen and resident beneficiaries of offshore estate planning structures were significantly affected.

This course, presented by estate planning attorney Christiana Lazo, introduces the controlled foreign company (CFC) rules, before exploring select changes to the CFC rules which were introduced by the Tax Cuts and Jobs Act. The course will utilize illustrations from common structures to demonstrate the effect of the relevant changes.

Learning Objectives:

  1. Review the CFC rules, particularly their relevance to estate planning techniques
  2. Explore the changes to the CFC rules introduced by the Tax Cuts and Jobs Act, including changes to the definition of a US shareholder, expansion of attribution rules with downward attribution, elimination of the “30-day rule”, the new GILTI tax regime, and the transition tax on deferred foreign income of CFCs and other specified foreign corporations
  3. Analyze how the changes to the CFC rules affect common estate planning structures, and consider techniques to mitigate the effect of the changes on clients


Christiana Lazo

Ropes & Gray LLP

Christiana Lazo is counsel at Ropes & Gray LLP in its New York office. Her practice consists of representing ultra-high net worth individuals, their family offices, and closely held businesses in developing and implementing sophisticated domestic and international tax and estate plans. She has significant experience counseling global clients on inbound and outbound planning, particularly advising families with members in multiple jurisdictions on wealth transfers and on tax-efficient investment and business ownership structures.

Christiana is an adjunct professor at the New York University School of Law, where she teaches Generation-Skipping Transfer Tax, and a frequent speaker and author on estate planning topics.


Carey B.

Excellent discussion.

Christina C.

Great, organized speaker!

Christopher R.

Presenter was very enjoyable and clear about unfamiliar and somewhat complicated subject matter. Also well paced.

Heather C.

This CLE was outside my practice area, but the presenter was extremely well prepared and well-versed in the topic and presented in a way that I was able to follow the more complex issues. Interesting.

Leslie A.

The presenter was very-well organized and presented a difficult topic in an easy to understand format, in a timely fashion.

Paul M.

Easy to use, thanks.

Trevor B.

A polished presentation!

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


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