International Planning

This year’s Institute features a series of programs on International Planning. This series recognizes the increasing prevalence of clients with international connections, this series provides an overview of the international planning concepts all planners should be familiar with, as well as an introduction to employment and immigration law. It also examines planning with community property, and U.S. tax issues related to foreign trusts.

Wednesday, January 24, 2018   (9:50 – 10:40 a.m.)
Theory Meets Reality: A Practical Look at the U.S. Income Taxation of U.S. Grantors and Beneficiaries of Foreign Trusts
M. Read Moore

Differences in trust law and trust administration outside of the United States often make advising U.S. clients on U.S. tax issues related to foreign trusts quite challenging. This presentation will address the principal U.S. income tax issues affecting U.S. settlors and beneficiaries of trusts administered outside the United States with an emphasis on frequent conflicts between U.S. tax law and the realities of trust law and trust administration outside of the United States.

Wednesday, January 24, 2018   Special Session I-C   (2:00 – 3:30 p.m.)
Two Systems Separated by a Common Language: U.S. Tax Law Meets Non-U.S. Trust Law
M. Read Moore, Alec R. Anderson

This session will consider the application of U.S. income tax laws to trusts administered outside the United States in the context of non-U.S. trust law and typical administrative practices of non-U.S. trustees, including issues related to the establishment and settlement of non-U.S. trusts, trust administration outside the United States, distributions from foreign trusts, and termination of foreign trusts.

Thursday, January 25, 2018   (9:00 – 9:50 a.m.)
Stranger in a Strange Land:  Dealing with Foreign and Domestic Community Property Issues in Your State
Joshua A. Rubenstein

People are becoming increasingly peripatetic in today’s mobile society. Sometimes people from different countries marry. Sometimes couples change domiciles. Sometimes, individuals have property in more than one country. And sometimes, individuals have close family members, even spouses, who live in different countries. This program will consider the issues presented when an individual from a community property jurisdiction has connections to a common law property jurisdiction.

Thursday, January 25, 2018   Fundamentals Program   (2:00 – 5:20 p.m.)
Demystifying International Tax Planning for Individuals – A Primer for the Domestic Estate Planner
N. Todd Angkatavanich, Scott A. Bowan, Carlyn S. McCaffrey, Edward Vergara

This program will focus on tax issues practitioners should be familiar with when dealing with families who have multi-national members and assets, including U.S. income and transfer tax rules relevant to residents and non-residents, inbound and outbound investments, foreign trusts and their U.S. beneficiaries, corporate anti-deferral regimes, and expatriation. We will also discuss information exchange regimes such as FATCA, CRS and more.

Thursday, January 25, 2018   Special Session III-F   (3:50 – 5:20 p.m.)
Employment and Immigration Law 101
Linda M. Doyle, Elizabeth A. Quinn

High net worth families (and family offices) should have a working knowledge of employment issues – both those impacting family employees and staff at the family office. This session will focus on issues unique to family (domestic) employees such as the Fair Labor Standards Act, classification as an employee versus independent contractor, and liability. It will also address issues related to more high-level employees of the office, including hiring, compensation, performance reviews, terminations, and liability. Finally, it will address issues related to employing non-U.S. citizens.