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International Trust and Estate Planning--2004

These materials deal with estate planning both for the foreign client with U.S. connections, which may include family members or active or passive investments, and for the U.S. client with foreign connections. In our increasingly multinational world, the sophisticated estate planner cannot practice effectively without knowledge of the special tax and non-tax rules that come into play for these types of clients. Substantial changes in the tax and reporting rules affecting foreign trusts, trusts established by foreign grantors, and U.S. tax expatriates are discussed in depth, as are the regulations and procedures under them. The complementary tax regimes affecting foreign corporations with U.S. shareholders also are examined. What constitutes a controlled foreign corporation (CFC), foreign personal holding company (FPHC), or passive foreign investment company (PFIC)? What is the significance of status as one or another? How do the rules governing these entities interact with the rules governing trusts? Other topics include: what can and cannot be accomplished through an asset protection trust; civil law analogs to the common law trust; income, gift, and estate taxation of nonresident aliens; tax treaties; marital planning for the non-citizen spouse; foreign private placement insurance; important non-tax issues in cross-border estate planning; and the opportunities and pitfalls of expatriation. CK024

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Coursebook Papers:

Taxation of Nonresident Aliens (42 pp) $29.00

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Basic U.S. Transfer and Income Tax Rules Applicable to Non-Resident Aliens (38 pp) $29.00

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Effects of Tax Treaties on U.S. Activities of Nonresidents (34 pp) $29.00

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Foreign Trusts and Alternative Vehicles (26 pp) $29.00

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U.S. Taxation of Foreign Trusts, Trusts with Non-U.S. Grantors and Their U.S. Beneficiaries (80 pp) $39.00

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CFCs, PFICs and FPHCs in Foreign Trusts (10 pp) $29.00

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Planning for the Payment of Estate Tax Attributable to Transfers to Non-U.S. Citizen Spouses (40 pp) $29.00

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Cross-Border Canadian-U.S. Planning (22 pp) $29.00

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Asset Protection Trusts (APTs): Non-Tax Issues (183 pp) $49.00

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Offshore Private Placement Life Insurance Planning (56 pp) $39.00

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Expatriation: The Ultimate Estate Planning Tool? (44 pp) $29.00

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