SAVE $200 Register by June 30, Use Code: CX013EBB

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1 31st Annual Advanced Course EARLY BIRD DISCOUNT SAVE $200 Register by June 30, Use Code: CX013EBB International Trust and Estate Planning Thursday-Friday, August 13-14, 2015 San Francisco (Bar Association of San Francisco Conference Center) and Live Video Webcast Register online: 14 CLE credit hours, including 2 hours of ethics 16 CPE credit hours in Taxation If you provide tax and trust advice to U.S. clients with international connections or to foreign clients with U.S. connections (or if you are a sophisticated professional looking to expand your practice), you must attend this program! Set in San Francisco, International Trust and Estate Planning gives you the information and practical strategies you need for advising both U.S. and international clients in this complex and alwayschanging area. New and updated discussions address the full range of issues confronting international tax planning practitioners, including compliance with the Foreign Account Tax Compliance Act (FATCA), among many others. Very good range of topics.the interactive format with input from panel members and questions from audience during talks made it more engaging and dynamic. previous attendee

2 Planning Chairs (also on faculty) M. Read Moore McDermott Will & Emery LLP, Menlo Park, California Michael G. Pfeifer Caplin & Drysdale, Chartered, Washington, D.C. Faculty Mark John Barmes Lenz & Staehelin, Geneva, Switzerland Henry Christensen III McDermott Will & Emery LLP, New York Michelle B. Graham McKenna Long Aldridge LLP, Rancho Santa Fe, California Ellen K. Harrison Pillsbury Winthrop Shaw Pittman LLP, Washington, D.C., ALI Member Jonathan Jackel Burt Staples & Miner, LLP, Washington, D.C. Mark E. Matthews Caplin & Drysdale, Chartered, Washington, D.C. Carlyn S. McCaffrey McDermott Will & Emery LLP, New York John C. McDougal Counsel, Small Business/Self-Employed Division, Internal Revenue Service, Richmond, Virginia (invited) Michael J. Miller Roberts & Holland LLP, New York Mark E. Osborne Osborne, Helman, Knebel & Deleery, L.L.P., Austin, Texas Stephen Trow Trow & Rahal, P.C., Washington, D.C. Bruce Zagaris Berliner, Corcoran & Rowe, LLP, Washington, D.C. ALI CLE Program Attorney: Kevin J. O Connor (koconnor@ali-cle.org) Here s what registrants have said about recent presentations of this course: Fourth time attending. Course great as always. I particularly enjoyed the current development portions of the presenters talks. This was a nearly perfect course. Attorneys Christensen and Moore were top-notch presenters!

3 Program All times Pacific Time. Thursday, August 13, :45 a.m. Registration and Continental Breakfast 8:40 a.m. Administrative Remarks ALI CLE Staff Video Webcast Segment A $329 8:45 a.m. Opening Remarks and Course Overview Messrs. Moore and Pfeifer 8:50 a.m. Trusts and Alternative Vehicles Mr. Christensen U.S. tax definition of trust ; U.S. tax treatment of civil law constructs (anstalts, foundations, and usufructs); civil law treatment of common law trusts, including recent case law; and effect of the Hague Convention 9:40 a.m. Estate Planning for Nonresident Aliens Mr. Miller Domicile as the basis of taxation; substantive gift, estate, and GST tax rules; planning for NRAs with U.S. situs property; and use of estate and gift tax treaties 10:20 a.m. Networking and Refreshment Break 10:35 a.m. Planning for U.S. Clients with Foreign Property Ms. Graham Legal and tax issues that arise when U.S. citizen and resident clients own property in foreign countries, including real estate, business interests, and financial accounts 11:25 a.m. Tax Compliance Issues for U.S. Clients with Foreign Income and Foreign Assets Mr. Moore Multiple informational forms that U.S. citizen and resident clients who have foreign income and foreign assets must file, including FINCen Form 114 (FBAR), Form 8938, Form 3520, and forms for owners of interests in non-u.s. businesses and companies 12:15 p.m. Questions and Answers 12:30 p.m. Networking Lunch for Registrants and Faculty (provided by ALI CLE) Video Webcast Segment B $329 1:45 p.m. FATCA and Foreign Trusts and Trustees Mr. Jackel Foreign Account Tax Compliance Act (FATCA) regime as it relates to foreign trusts, trustees, and underlying private investment companies; parallel analysis of the regime as administered under an Inter-Governmental Agreement (IGA). What should a trustee or trust company tell its beneficiaries or clients? Will the FATCA rules be harmonized with those of the G-20 s Common Reporting Standards (CRS) when rolled out? What do these regimes portend for the historic confidentiality of trusts? 2:30 p.m. FATCA and Compliance Issues Messrs. Barmes, Christensen, Jackel, Moore, Pfeifer, and Zagaris Important recent developments related to the Foreign Account Tax Compliance Act (FATCA) and IGA regimes from both the payor side and the payee side. The panelists will offer practical advice to advisers and clients struggling with the continuous developments in this complicated area. 3:20 p.m. Networking and Refreshment Break

4 3:30 p.m. Ethical Issues in Offshore Planning (with Ethics Roundtable) Mr. Zagaris and panel Application of due diligence and know-your-client principles to lawyers involved in wealth planning and management; update on anti-tax haven initiatives: organization for Economic Cooperation and Development (OECD), Financial Action Task Force (FATF), Financial Stability Forum (FSF), etc.; and limits on bank secrecy and practical lessons of dealing with increasingly complex tax and regulatory regimes 5:30 p.m. Adjournment for the Day Friday, August 14, :00 a.m. Continental Breakfast and Networking Session Video Webcast Segment C $329 8:30 a.m. Inbound Planning with Foreign Trusts (Including Planning for Underlying Foreign Companies) Mss. Harrison and McCaffrey U.S. taxation of foreign grantor trust and foreign non-grantor trust structures at both the trust level and the beneficiary level, including reporting-related issues; and important commonly encountered non-u.s. trust law issues and issues related to foreign business entities held in trust structures, including the controlled foreign corporation and passive foreign investment company rules 10:10 a.m. Networking and Refreshment Break 10:25 a.m. Trust and Tax Law Developments Outside the U.S. Mr. Barmes Important developments and trends in offshore financial centers that affect U.S. advisers who have clients with foreign property and financial accounts and interests in foreign trusts, including developments in Switzerland 11:15 a.m. Offshore Asset Protection Trusts Mr. Osborne A review of the principles underlying the use of trusts for asset protection purposes. What are the proper purposes of asset protection trusts, and are there any limits to their use? What factors should be considered in choosing the best jurisdiction? What are the pros and cons in using domestic or foreign asset protection trusts? 12:05 p.m. Questions and Answers 12:15 p.m. Lunch Break Video Webcast Segment D $329 1:30 p.m. Immigration and Related Planning Mr. Trow Immigration planning for high net worth clients; common nonimmigrant (temporary) visas; investment-based options for obtaining permanent resident (green card) status; and obtaining and terminating U.S. citizenship 2:20 p.m. Expatriation Mr. Pfeifer Expatriation provisions after 2008 HEART Act changes; problems with scope and administration of mark-to-market, deferred compensation, and non- grantor trust provisions; new Section 2801 inheritance tax; and practical issues with advising citizens and long-term residents

5 3:10 p.m. Networking and Refreshment Break 3:25 p.m. Compliance Initiatives/ Voluntary Disclosure Mr. Matthews Latest developments in U.S. government initiatives to encourage and compel compliance with U.S. tax laws with respect to U.S. citizen and resident clients with foreign income and foreign assets 4:15 p.m. Offshore Voluntary Disclosure Initiative (OVDI) and Other Initiatives Mr. McDougal 5:05 p.m. Questions and Answers 5:15 p.m. Adjournment Total 60-minute hours of instruction: 14, including 2 hours of ethics 16 CPE credit hours in Taxation (live group and group-internet-based program) Take advantage of the early bird discount AND SAVE $200! Register for the in-person program by June 30, Use Code: CX013EBB ALI CLE CURRICULUM: ESTATE PLANNING ALI CLE continues to be the premier source of relevant continuing legal education for estate planners of all experience levels. Ranging from hot topics to basic overviews, our top-notch courses cover a wide range of topics, including family business deals, buy-sell agreements, estate planning for second marriages, asset protection trusts and agreements, and practical tax guidance. These programs, taught by preeminent estate planning experts, provide helpful instruction to estate and trust administration attorneys and professionals, risk managers, investment officers, and financial planners.

6 HOW TO REGISTER ONLINE PHONE CLE NEWS FAX MAIL Return the form on the back panel of this brochure to: REGISTRAR, ALI CLE 4025 Chestnut Street Philadelphia, PA REGISTER TWO OR MORE AND SAVE! Register one person to attend this course in-person and get all subsequent in-person registrations for this course from your organization at 50% off! Call CLE-NEWS ( ). Discounts may not be combined. COURSE LOCATION The course will be presented at the Bar Association of San Francisco (BASF) Conference Center, 301 Battery Street, 3rd Floor, San Francisco. Nearby parking garages include: One Embarcadero, (415) ; Two Embarcadero Center, (415) , and One Maritime Plaza, 300 Clay Street, San Francisco (415) HOTEL ACCOMMODATIONS A limited block of rooms has been reserved at Le Meridien San Francisco, about a block from the BASF Conference Center. Room rate: $279 per night, single or double occupancy. These rooms will be held as a block, unless exhausted, until July 13, at which time they will be released to the general public. Registrants must make their own hotel reservations and indicate that they are attending the ALI CLE course to qualify for rooms in the block. Room reservations may be made by calling Le Meridien San Francisco, 333 Battery Street, San Francisco, CA 94111; phone or Confirmations will be sent by the hotel. Please read the cancellation policy carefully. STUDY MATERIALS AND USB DRIVES Registrants have the options of receiving their study material as a printed course book OR on a USB drive. Be sure to indicate your preference when you register. Go Green! Select the USB option! NETWORKING OPPORTUNITIES Networking is an important reason to attend this and every other ALI CLE course. Registrants for last year s presentation of this course came from 20 states! Go to for more info about: registration/cancellation/requirements for persons with disabilities/scholarships MANDATORY CLE AND CPE CREDIT Virtually all ALI CLE programs receive CLE credit in AK, AL, AR, AZ, CA, CO, DE, FL, GA, HI, IA, IL, IN, KS, KY, LA, ME, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, PA, RI, SC, TN, TX, UT, VA, VT, WA, WI, and WV. Upon request, ALI CLE will apply for CLE credit in ID, OR, and WY. This course is expected to qualify for 14 credits, including 2 ethics credits, in 60-minute MCLE jurisdictions; and for 16.8 credits, including 2.4 ethics credits, in 50-minute MCLE jurisdictions. In NY, the in-person course is appropriate for both newly admitted and experienced attorneys. For specific information on CLE, CPE, or other professional accreditation in your state, please the MCLE Team at TeamMCLE@ali-cle.org, go to ali-cle.org/mcle, or call CLE-NEWS. NASBA ALI CLE is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors through its website: For more information regarding ALI CLE s administrative policies, such as complaint and refund, please call Customer Service at (800) CLE-NEWS. CPE credit hours for this course: 16 in Taxation (live group and group internet-based programs). Learning Objectives: Acquisition of knowledge and skills to develop proficiency as a practitioner; maintenance of professional competence as a practitioner. Suggested Prerequisite: Experience in practice in subject matter. Level of Instruction: Advanced. Catch the fever. Create a buzz with social networking. Tweet today and interact with other course registrants and faculty. Consider posting new course topics and pose questions you have for the faculty. Or simply use this social networking tool to make lunch or dinner plans with others in attendance. #InternationalTrust15

7 International Trust and Estate Planning Register online: Get expert analysis and critical insights into the complexities of today s cross-border trust and estate practice. Join an all-star faculty including a representative of the IRS who will address current offshore compliance and enforcement initiatives to explore the practical applications of the complex U.S. income, gift, and estate tax rules on noncitizens living or investing in the U.S., as well as on U.S. clients who own foreign property, have foreign financial accounts or interests in foreign entities, or are beneficiaries of offshore trusts or trust-like vehicles. Also delve into the latest country-specific developments outside the U.S., as well as important multi-country initiatives related to tax compliance, bank secrecy, and the prevention of money laundering. Special emphasis will be given this year to U.S. compliance initiatives, including newly expanded coverage of the Foreign Account Tax Compliance Act (FATCA). Other topics, new or updated for 2015, include: how U.S. clients should acquire or dispose of non-u.s. property compliance issues for U.S. clients with foreign income and foreign assets offshore asset protection trusts tax and trust law issues for U.S. settlors and beneficiaries of foreign trusts civil law analogues to the common law trust recent developments with voluntary disclosure of offshore financial accounts immigration and nationality concerns relevant to high net wealth individuals moving to and from the U.S. ethical issues in complying with overlapping rules and regulations while dealing with international clients In addition to its high-level, practical instruction, this program boasts an interactive format that gives you an outstanding opportunity to discuss your questions and network with faculty members and colleagues from around the world. WHO SHOULD ATTEND Attorneys, accountants, and financial planners with cross-border practices, as well as trust officers of U.S. or foreign banks, will benefit from attending this course.

8 American Law Institute Continuing Legal Education 4025 Chestnut Street, Philadelphia, PA NONPROFIT ORG U.S. Postage PAID ALI CLE KEY CODE CX013LM Name Title Firm Address City State Zip printed on FSC certified paper Online Phone CLE NEWS FAX Mail Registrar, ALI CLE, 4025 Chestnut Street, Philadelphia, PA International Trust and Estate Planning San Francisco, August 13-14, 2015 $1,399 Please enter early bird registration(s) (before 6/30/15): $1,199 CX013EBB Please enter registration(s): $1,399 CX013 Please provide my course materials as a (choose only one): USB drive Printed course book To register additional on-location registrants at 5 0 %o ff, call 800-CLE-NEWS ( ). Discounts may not be combined. Video Webcast $1,099 / $329 Full program. Tuition: $1,099 WAX013 Webcast Segment A: $329 WAX013A Webcast Segment B: $329 WAX013B Webcast Segment C: $329 WAX013C Webcast Segment D: $329 WAX013D Can t attend? You don t have to miss anything! Order the: DVD (video), including a complimentary MP3 CD-ROM and PDFs of the course materials $899 AX013V Audio MP3 CD-ROM (including PDFs of the course materials) $699 AX013 Printed course materials only $149 SX013 Partial Scholarships Scholarships covering 30% of tuition fees, valid for on-site courses, live webcasts, and webcast segments only, are available. Scholarships cannot be combined with other offers. I am a full-time employee of the federal, a state, or a local government or governmental agency. I am a recent law school graduate (<5 years). I am a retired senior lawyer (65 or older). $ Total Check enclosed (payable to ALI CLE) Please charge to my credit card: AMEX DISCOVER MasterCard VISA Card no.: Card expiration date: / SIGNATURE ADDRESS (REQUIRED FOR WEBCASTS AND ONLINE SUBSCRIPTIONS) CX013