Tax Planning for Non-Resident Aliens with U.S. Assets or Beneficiaries

Estate planning has an increasingly international flair because clients and their beneficiaries have broader global reach. This program, presented by Moses & Singer LLP partner Gideon Rothschild, will begin with a primer on planning for foreign clients who have domestic property or U.S. beneficiaries, including steps that should be taken if the client intends to immigrate to the United States. The program will also cover foreign vs. domestic trusts, tax reporting, accumulation penalties and proposed regulations under 26 U.S. Code § 2801 concerning gifts, and bequests from covered expatriates.

Learning Objectives:

1. Discuss the principles of Income, Gift, and Estate Taxation of Non-Resident Aliens (“NRAs”)
2. Recognize local law considerations in representing foreign clients with U.S. property or U.S. clients with foreign property
3. Consider how to avoid estate tax, where possible, on U.S. situs assets
4. Navigate gift and estate planning for NRAs with U.S. assets/beneficiaries
5. Comprehend gift tax rules for covered expatriates
6. Identify pre-immigration planning considerations for foreign clients