Planning Tips and Pitfalls for International Estate Planners
Presented by Carl A. Merino, Attorney, Day Pitney & Dina Kapur Sanna, Attorney, Day Pitney
12:00 PM - 12:15 PM - Opening Remarks
12:15 PM - 1:30 PM - Presentation and Q&A
Description: Our session will provide participants with key planning points to consider in working with international private clients, whether advising non-US clients on “inbound” gifts or investments or advising US clients with planning and reporting for assets overseas. Our session will walk participants through a number of issues and scenarios, including:
- Overview of estate, gift and income taxation of nonresident aliens – differing definitions of residence, situs rules of different assets classes, lower estate tax exemption for nonresident aliens and ways to mitigate estate taxation through the use of treaties, “blocker” entities and lifetime gifts of intangibles
- Potential pitfalls of using foreign trusts – residency of trusts, difficulty qualifying trust with nonresident alien grantor as grantor trust, throwback rules and anti-deferral rules
- Structuring gifts from non-US donors to US donees – cash gifts, gifts in trust
- Foreign asset reporting for US individuals with foreign financial assets and IRS compliance efforts
- Planning with a noncitizen spouse – unintended estate and gift tax consequences of joint ownership of assets, QDOT planning
||Carl Merino represents U.S. and non-U.S. families and companies on a wide range of personal and business tax matters, including cross-border income and estate tax planning, corporate and partnership tax issues, S corporations and income taxation of trusts and estates.
Carl works extensively in the international tax arena. He advises non-U.S. clients on structuring inbound investments to minimize federal and state income and estate tax exposure. He advises U.S. clients on tax aspects of foreign investments, including anti-deferral rules, entity classification issues and reporting requirements for foreign entities and trusts. His work in this area also encompasses pre-immigration and expatriation planning, tax issues of foreign trusts with U.S. beneficiaries, cross-border compensation and employment tax issues and corporate structuring for foreign companies setting up U.S. operations.
Carl is co-chair of the International Estate Planning Committee of the New York State Bar Association's Trusts and Estates Law Section. He frequently publishes articles on various aspects of cross-border tax planning.
| ||Dina Kapur Sanna has over 20 years of experience in advising U.S. and non-U.S. taxpayers on wealth management structures which accommodate multi-jurisdictional tax and legal considerations. Her practice involves foreign trusts, pre-immigration and expatriation planning, planning for the purchase of U.S. property by non-U.S. persons and compliance with tax and reporting obligations for those with overseas interests in foreign accounts, corporations and trusts.|
Dina is recognized as a leading international estate planning attorney by Chambers HNW* (Chambers & Partners), Chambers Global*, Private Client Global Elite (ALM Media Properties, LLC), and The International Who's Who of Private Client Lawyers. In the 2018 edition of Chambers HNW, they note that Dina advises on a full range of wealth management matters, including trusts and immigration planning for affluent families. They quote one source who said, "She is so responsive, it's unbelievable. There is no question she can't answer in 24 hours. She's also very passionate and very good at explaining complicated laws and regulations to clients, especially in tax." Chambers HNW quote another interviewee who enthused, "I think she is outstanding. I have always found her to be extremely bright, practical and a nice person with whom to work."
Dina is a frequent speaker at estate planning seminars around the world. She has written numerous articles that appear in legal periodicals in the U.S. and abroad. Dina is a fellow of the American College of Trust and Estate Counsel (ACTEC) and a member of its International Estate Planning Committee. In addition, she is an Academician of The International Academy of Estate and Trust Law. She also was a former member of the Firm's Executive Board.
* No aspect of these advertisements has been approved by the highest court of any state. See Awards Methodology.
Members - $10.00
Non-Members - $20.00
Registrants will receive a link to the live GoToWebinar event 24 hours in advance.
Category of Track: Legal
Level of Track: Technical
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