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International Trust and Estate Planning--2003

This advanced course book deals 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. "Inbound" issues are covered on the first day of the course, "outbound" issues on the second. 1996 brought substantial changes in the tax and reporting rules affecting foreign trusts, trusts established by foreign grantors, and U.S. expatriates. These 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 analogies to the common law trust, marital planning for the non-citizen spouse, foreign private placement insurance, international charitable planning, and the opportunities and pitfalls of expatriation. CJ027

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Coursebook Forms:

International Charitable Planning (with Forms) (2003) (0 pp) $39.00

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Coursebook Papers:

Basic U.S. Transfer and Income Tax Rules Applicable to Non-Resident Aliens (0 pp) $29.00

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Effect of Tax Treaties on U.S. Activities of Nonresidents (0 pp) $29.00

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Foreign Trusts and Alternative Vehicles (0 pp) $29.00

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Developments in Ethics (0 pp) $29.00

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Attribution of Ownership of Corporations Held by Trusts (0 pp) $29.00

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Asset Protection Trusts (APTs): Non-Tax Issues (0 pp) $39.00

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Asset Protection Trusts (APTs): Jurisdictional Comparison (0 pp) $29.00

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Foreign Insurance Products (11 pp) $29.00

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Planning for the Payment of Estate Tax Attributable to Transfers to Non-U.S. Citizen Spouses (0 pp) $29.00

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Expatriation: The Ultimate Estate Planning Tool? (0 pp) $29.00

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