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Part 3: Mark Merric’s Three-Part International Estate Planning Series



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Planning for foreign persons with U.S. property, for U.S. and foreign persons with noncitizen spouses, as well as for the use of foreign trusts, differs greatly from most domestic estate planning concepts that advisors are comfortable with. Mark Merric’s exclusive 3-part LISI Webinar series will help you sharpen your international estate planning skills, help you learn how to quickly identify the issues, and allow you to develop new and modify existing estate plan designs for foreign clients as well as  those that have non-citizen spouses.  

Part 1 (“The Basics of International Estate Planning”) identifies the differences between foreign persons and U.S. persons and addresses the basic estate planning tools used for international estate planning.  Whether it is a U.S. person or a foreign person that has a noncitizen spouse, there is no unlimited marital deduction.  Part 2 (“The Noncitizen Spouse & U.S. Estate Tax Treaties”) addresses key gift issues that need to be addressed when dealing with these clients, as well as why Mark dislikes QDOTs.  It also covers some of the key concepts in U.S. estate tax (and sometimes gift tax) treaties the U.S. has with 14 nations.   Part 3 of Mark’s content-packed series (“Advanced International Estate Planning With Trusts”) looks at high net worth foreign persons that intend to own significant assets in the U.S., and discusses using domestic and foreign trusts in the estate planning process.  You can register for the entire series at a special limited time discount by Clicking This Link. 

Mark’s 3-part series is ideal for anyone advising wealthy, international clients. In each 90-minute session, Mark will cover the following concepts, and much more: 

I.       The Basics of International Estate Planning September 11th @ 3pm

Ø A U.S. person has an applicable exclusion of $11.58 million.  A foreign person has a mere exclusion of $60,000, meaning if a foreign person directly owns a single $300,000 U.S. residential rental property free and clear, the estate tax would be $74,800.

Ø A U.S. person has an unlimited marital deduction gift and estate taxation.  Conversely, a foreign person has no marital deduction, but can gift $157,000 (Indexed 2020) per year.

Ø A U.S. person is taxed on world-wide assets.  Conversely, a foreign person is taxed on U.S. situs assets for estate purposes.  However, can a foreign person gift intangible assets without a gift tax?

Ø How are classification of a taxpayer (U.S. or foreign), source of income, and situs of assets related.  More important, how are they different, in particular as applied to using LLC’s and FLP’s in tax planning?

Ø What do other countries think about the U.S. style LLC that is also found in six island countries and Belize? 

Ø Can a foreign person transfer an existing U.S. business to a foreign corporation and avoid estate tax, or do the inversion rules apply, which nullify this estate planning tool?

Ø Q&A

 

II.      The Noncitizen Spouse & U.S. Estate Tax Treaties October 9th @ 3pm ET

Ø A foreign person or U.S. person buys a U.S. vacation home in joint tenancy with a noncitizen spouse.  Does creation of joint tenancy create a gift?

Ø Of course it creates a gift, if it is a foreign person making the gift, there is no unlimited marital deduction.  Rather, an annual IRC § 2503(b) gift amount of $157,000 (Indexed 2020) and after that the lifetime applicable exclusion of a whopping $60,000.

Ø Is a QDOT merely a delay vehicle that delays U.S. estate taxation to the death of the second spouse for a noncitizen spouse?

Ø Why are large QDOTs so expensive and administratively inconvenient?

Ø Fourteen nations have estate tax treaties with the U.S. and some also have gift tax treaties.  Who are these nations?

Ø What are the key provisions in a typical estate tax treaty?

Ø Q&A 

 

III.     Advanced International Estate Planning With Trusts October 23rd @ 3pm ET

Ø Why do grantor trust rules and therefore the advanced planning with IDITs typically fail for foreign persons?

Ø Why foreign trusts may result in some unintended U.S. estate tax results?

Ø What was the one case where the famous Judge Learned Hand was simply wrong, or you hope so?

Ø Can a foreign person use a domestic trust for U.S. estate planning?

Ø How should these trusts be drafted?

Ø What states or trust jurisdictions should be used when drafting these trusts?

Ø Why is FACTA (that horrible banking law causing all international business transactions grief) the 400 lb Gorilla sitting by any trust planning?

Ø Q&A

In addition to being a certified public accountant, Mark Merric is an attorney and, holds a masters of taxation. He is a lecturer at the University of Colorado Denver Masters of Taxation and at Fudan University, China (typically ranked from 2nd to 4th in China). He also served as an adjunct professor for the University of Denver Graduate Tax Program for 20 years. Mr. Merric is the manager of Law Firm of Mark Merric, LLC where he concentrates on international business transactions, international taxation, and business structures. Mark Merric has over thirty years of business experience working for a Final Four accounting firm, Fortune 500 Company, one of Denver’s oldest and largest law firms, Holme, Roberts & Owen, LLP (“HRO”), as well as local CPA firms and law firms. Mark has spoken at over 600 seminars, and currently he speaks internationally over a dozen times a year. He has spoken 50 times in China.

 



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