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This program will provide the participant with the fundamentals of the taxation of foreign trust distributions received by a U.S. taxpayer, and an understanding to avoid penalties associated with accumulated foreign trust income (i.e., Throwback Tax). Additionally, participants will be exposed to civil law wealth transfer structures and determination of their U.S. tax implications and the implications utilizing offshore companies as part of the wealth transfer structure.
Topics of discussion will include:
More and more families are using the U.S. for trust and family wealth structuring, which is generally a derivative of their offshore structure. Many of these families have a connection to the U.S. by way of family members being U.S. citizens or U.S. permanent residents (green cardholders). FATCA and CRS generally require the reporting of some of the assets within the structure to the U.S. and parties to CRS. So, it is very important to understand:
For over 25 years, Jack has specialized in wealth tax matters for international private clients. He is widely published on various matters in the U.S. and abroad. He presents at international, as well as domestic conferences, on various international private client matters and investment, in the U.S. real property. He acts as outside counsel and consultant for a number of U.S. and foreign trust companies, on highly complex foreign trust matters.
In 2004, Jack had an article published in Trusts & Estates professional journal, namely, Foreign Trusts: The Capital Loss Debate. This article is still regarded, in the professional community, as the standard for U.S. tax treatment of net capital losses for U.S. beneficiaries of foreign non-grantor trusts.
