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Alison Egan Addresses Cross-Border Estate Planning at ABA May Meeting

May 11, 2019, 2:00 PM - 5:15 PM ET
Program:Welcome to International Private Client: Fundamentals of Cross-Border Estate Planning Workshop
Event Sponsor:2019 ABA Section of Taxation May Meeting

Grand Hyatt Washington
1000 H Street NW

Washington, DC 20001

Registration:Click Here To Register

IRS and private practitioners will present a three-part workshop that will focus on the fundamentals of international private client. This workshop is intended to be an introduction to the international private client practice for junior attorneys and a refresher for more seasoned practitioners. The workshop will be divided into three panels: Cross-border Estate Planning, Estate and Gift Tax Treaties, and Foreign Trusts.

This panel will focus on provisions of the U.S. tax code relevant to assessing and implementing cross-border estate planning. Points of discussion will include identifying that tax status of the taxpayer and the taxpayer’s family (i.e. citizenship, tax residency, domicile), the type and situs of the taxpayer’s worldwide assets (i.e. tangible or intangible and U.S. or foreign), the impact of income and estate tax treaties (also see the third session below “Estate and Gift Tax Treaties” for a more thorough analysis), and common planning pitfalls and considerations (i.e. blocker entities, trusts, FIRPTA, outbound transfers, inversions, PFICs, and CFCs).

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