BarbriSFCourseDetails
  1. keyboard_arrow_leftBack

Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Tuesday, February 25, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00

This CLE/CPE course will focus on counsel's and tax advisers' challenges in estate planning for resident and nonresident aliens, focusing on relevant tax rules and potential estate planning pitfalls and opportunities. The panel will outline and analyze hypothetical estate planning scenarios for both groups.

Faculty

Packman Kevin
Shareholder
Holland & Knight LLP

Mr. Packman is an ACTEC Fellow and partner in Holland & Knight LLP’s Private Wealth Services Section where he leads the firm’s International Estate Planning Group. Mr. Packman’s practice includes advising high-net-worth private clients (whether U.S. or foreign) with tax, trusts and estates. This also includes pre-immigration planning and expatriation planning. He also helps clients come into compliance and resolve tax controversies.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Kayan Marianne
Shareholder
Ernst & Young

Ms. Kayan leads a collaborative team of professionals to address the cross border needs of high net-worth business connected individuals. Since 2010, she has been a key developer of EY Private's cross border team. Ms. Kayan focuses on teaming with EY affiliated firms and other subservice lines to offer exceptional global client service.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Levin Jeffrey
Shareholder
Parent: Squire Patton Boggs

Mr. Levin’s practice includes federal, state and local taxation; estate planning, trusts and estates administration; charitable giving; and succession planning for closely held businesses.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio

Description

With increasing high net worth clients acquiring citizenship or permanent residency in multiple countries, counsel and tax advisers should recognize estate planning issues. Counsel's initial inquiry establishes whether a new client is a U.S. income tax resident and a U.S. domiciliary.

Spouses and children may have different citizenships and residency statuses, which will also impact the estate plan. Many nonresident aliens have children/grandchildren who are U.S. income tax residents. There may be significant transfer tax advantages of gifts and bequests from nonresident aliens to U.S. persons.

Estate planning attorneys and tax advisers must also identify tax opportunities and risks for clients, understand the reporting issues that apply to the U.S. recipients of gifts, and anticipate problems that arise when non-U.S. individuals acquire or transfer U.S. assets.

Listen as our panel of estate planning attorneys experienced in international issues discusses the estate, gift, and generation-skipping transfer tax rules for resident and nonresident aliens. The panel will also outline basic planning scenarios and key potential trouble spots and opportunities.

Outline

  1. Estate, gift, and generation-skipping transfer tax rules
    • U.S. residents
    • Non-U.S. residents
    • Effect of bilateral estate and gift tax treaties
  2. Sample estate planning scenarios
    • U.S. legal permanent resident married to U.S. citizen
    • Both spouses are U.S. legal permanent residents
    • Nonresident alien married to U.S. citizen
    • Nonresident alien with U.S. assets
  3. Potential trouble spots
    • Choosing executors/trustees
    • Children with different citizenships
    • Covered expatriates
  4. Potential opportunities
    • Gifts/bequests by nonresident aliens
    • Dynasty trusts
    • Reporting issues for U.S. recipients

Benefits

The panel will review these and other key issues:

  • What estate, gift, and generation-skipping transfer tax rules apply to resident and nonresident aliens?
  • What gift and bequest opportunities are available for transfer by nonresident aliens to U.S. persons?
  • What are the reporting issues for counsel when U.S. taxpayer clients are recipients of gifts and bequests from nonresident aliens?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize key challenges of estate, gift, and generation-skipping transfer tax rules
  • Ascertain when treaty provisions may trump income and transfer tax rules
  • Determine when income may be effectively connected with the U.S.
  • Decide appropriate holding structures for U.S. assets

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).