International Planning

This year’s Institute features a series of programs on International Planning. This series provides an update on international planning including recent developments and trends in global tax transparency, planning for non-U.S. persons investing in the U.S., and advising clients seeking U.S. tax deductions for international charitable donations.


Wednesday, January 11, 2017 (9:00 – 9:50 a.m.)
Around the World in 80 Donations, or Structures Supporting U.S. Deductions for Donations Spent Abroad
Victoria B. Bjorklund
How well prepared are you to advise clients seeking U.S. tax deductions for charitable donations where those donations will be expended outside the United States? This presentation will review the IRS-approved “American Friends of” structure and its cousin, the cross-border donor-advised fund. It will also identify traps for the unwary, particularly facts fatal to deductibility.
 

Wednesday, January 11, 2017 (9:50 – 10:40 a.m.)
Tax and Estate Planning Considerations for Foreign Persons Owning U.S. Assets
Michelle B. Graham
This program will address the U.S. income tax and transfer tax rules that apply to non-U.S. persons who invest in the United States. It will also discuss tax treaty planning and some of the foreign law considerations that may arise when planning for non-U.S. persons who invest in the United States.
 

Wednesday, January 11, 2017 Special Session I-C (2:00 – 3:30 p.m.)
International Recent Developments
Scott A. Bowman, Ellen K. Harrison, Dina Kapur Sanna
International tax planning has been in a dramatic state of change. This panel will address recent developments and focus on sweeping trends in global tax transparency.
 

Wednesday, January 11, 2017 Special Session II-E (3:50 – 5:20 p.m.)
Tax and Estate Planning Considerations for Foreign Persons Owning U.S. Assets: A Deeper Dive
Michelle B. Graham, Marnin J. Michaels, Joshua S. Rubenstein
This session will take a deeper dive into the tax and estate planning considerations for non-U.S. persons who are either contemplating purchasing U.S. assets or who already own U.S. assets. The session will assume a basic understanding of the U.S. tax laws. It will provide practical advice to the practitioner on tax and estate planning considerations for non-U.S. persons investing in the U.S., including a discussion of how best to hold title to U.S. assets.
 

Wednesday, January 12, 2017 Special Session III-D (2:00 – 3:30 p.m.)
Private Foundation Governance and Grantmaking: Practical Solutions to Everyday Dilemmas
Alan F. Rothschild, Jr., Victoria B. Bjorklund, Carolyn O. “Morey” Ward
This session will explore common private foundation issues through a series of hypotheticals including avoidance of excise taxes on foundation activities, governance, foreign grantmaking, and the interplay of foundations and donor- advised funds.