Description

This session will cover residency for income and transfer tax purposes, and discuss six issues including: revocable trusts and companies tainted by U.S. situated assets under section 2104(b), section 684 planning, section 2801 gifts and bequests from covered expatriates, planning for non-U.S. parents with U.S. beneficiaries, UNI, and CFC and PFIC related issues.

Learning Objective:

• Understand common pitfalls and learn how to mitigate exposure to U.S. income and estate tax in relation to estate plans involving foreign trusts and companies with U.S. situated assets, persons leaving the U.S., and U.S. beneficiaries.

Speaker(s):

• Leigh-Alexandra Basha, PARTNER, McDermott Will & Emery LLP
• Irene C. Estrada, JD, Managing Director, PwC