International Trust and Estate Planning

Transcription

1 REGISTER BY SEPTEMBER 29 AND S AV E $ 2 00 * OR American Law Institute CONTINUING LEGAL EDUCATION ADDITIONAL REGISTR ANTS SAVE 50%* SEE BACK FOR D E TA I L S Y E A R S OF EXCELLENCE IN C L E 20 TH ANNUAL ADVANCED COURSE and LIVE VIDEO WEBCAST International Trust and Estate Planning THURSDAY - FRIDAY NOVEMBER 9-10, 2017 SAN ANTONIO MARRIOTT RIVERWALK SAN ANTONIO, TEXAS REGISTER ONLINE w w w. a l i - c l e. o rg / C Z CLE-NEWS [ ] C L E C R E D I T H O U R S, INCLUDING HOURS OF ETHICS CPE CREDIT HOURS I N TA X AT I O N (group-live and group internet-based programs)

2 Planning Chairs (also on faculty) M. Read Moore McDermott Will & Emery LLP Michael G. Pfeifer Caplin & Drysdale, Chartered Faculty Mark John Barmes Lenz & Staehelin Sarah M.M. Duckham Trow & Rahal, P.C. Michelle B. Graham Withersworldwide Ellen K. Harrison McDermott Will & Emery LLP Jonathan Jackel EY (Ernst & Young LLP) Lucy S. Lee Akin Gump Strauss Hauer & Feld LLP Mark E. Matthews Caplin & Drysdale, Chartered Carlyn S. McCaffrey McDermott Will & Emery LLP Abel Francisco Mejia-Cosenza Sánchez Devanny Eseverri, S.C. Carolyn A. Schenck Senior Counsel, IRS Office of Chief Counsel (invited) John A. Terrill, II Heckscher, Teillon, Terrill & Sager, P.C. Brian P. Tsu Henderson, Caverly, Pum & Charney LLP ALI CLE Program Staff: Robert Rushton CLE CREDIT HOURS, INCLUDING 2.0 HOURS OF ETHICS 16.5 CPE CREDIT HOURS IN TAXATION I m actually sad the program is over. I loved it attendee Come to the premier international trust and estates course with the high-level information and strategies you need to advise both U.S. and international estate planning clients. Now in its 33rd year, International Trust and Estate Planning never fails to deliver. This year s program is no exception, with new sessions that explore current issues in foreign trust-related income tax, concerns involving non-resident aliens, and detailed guidance for staying vigilant when upholding anti-money laundering rules. As always, the course addresses perennial topics such as the complications encountered in estate planning for U.S. clients with foreign property and the complexities of planning for foreign trusts. SPECIAL FEATURE: Developments in Offshore Compliance and Enforcement An IRS representative will report on current initiatives aimed at identifying taxpayers using offshore accounts and other tax avoidance and evasion structures, as well as options available for correcting past noncompliance.

3 PROGRAM Go to to register online or for more information about the program, hotel accommodations, study materials, and CLE/CPE credit. November 9, :45 AM Registration and Continental Breakfast 8:50 AM Administrative Remarks ALI CLE Staff VIDEO WEBCAST SEGMENT A 8:55 AM Opening Remarks and Course Overview 9:00 AM Foreign Trust-Related Income Tax Issues This presentation will cover the U.S. fiduciary income tax rules that apply to foreign grantor trust and foreign nongrantor trust structures with respect to grantors, trustees, and beneficiaries, including reportingrelated issues. 10:40 AM Networking and Refreshment Break 11:00 AM Practical Issues for U.S. Clients with Foreign Trusts 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 interaction of U.S. income tax laws related to foreign trusts and their beneficiaries and the realities of trust law and trust administration outside of the United States. 11:50 AM European Developments This presentation will cover 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. 12:40 PM Lunch for Faculty and Registrants (provided by ALI CLE) VIDEO WEBCAST SEGMENT B 1:45 PM FATCA, CRS, and Beneficial Ownership Information Exchange This panel presentation will address recent developments in automatic tax information exchange, including FATCA and the Common Reporting Standard, as well as recent developments in beneficial owner registries, all with particular attention to how these developments affect globally mobile high net worth clients, including U.S. citizen and resident clients, and U.S. and non-u.s. trusts and trustees. 3:15 PM Networking and Refreshment Break This is the best panel I have ever experienced in a real estate CLE.

4 3:30 PM Anti-Money Laundering Rules and Other Ethics Issues This presentation will address due diligence and know-your-client principles in the United States and outside the United States that affect lawyers who work with clients on wealth management issues, with particular attention to initiatives of the Financial Action Task Force and the Organization for Economic Cooperation and Development (OECD) with respect to the participation of lawyers in the fight against money laundering and terrorist financing and the U.S. response to those initiatives. 4:30 PM Ethics Roundtable (All faculty) Faculty members will address important professional responsibility and ethics issues that affect lawyers who work with clients with crossborder issues and foreign trusts and trustees. 5:15 PM Adjournment for the Day November 10, :45 AM Continental Breakfast and Networking Session 9:35 AM Mexico-Related Issues This panel presentation will cover important rules that U.S. estate planning lawyers should know for U.S. clients who invest in Mexican property and for Mexican clients who move to and invest in the United States. 10:25 AM Networking and Refreshment Break 10:40 AM Immigration and Related Planning Immigration planning for high net worth clients; common nonimmigrant (temporary) visas; investment-based options for obtaining permanent resident (green card) status; obtaining and terminating American citizenship. 11:30 AM Expatriation Expatriation provisions after 2008 HEART Act changes; problems with scope and administration of markto-market, deferred compensation, and non-grantor trust provisions; new Section 2801 inheritance tax; practical issues with advising citizens and long-term residents. 12:30 PM Lunch Break (on your own) VIDEO WEBCAST SEGMENT C 8:35 AM Re-Cap of Day One 8:45 AM Estate Planning for U.S. Clients with Foreign Property 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. Overall course was excellent! These are by far the most informative seminars I have attended. The ALI CLE courses are the best for attorneys who have been practicing for more than five years. The topics are advanced enough where you always walk away having learned something. The faculty is fantastic, as are the materials.

5 Refreshment Break VIDEO WEBCAST SEGMENT D 1:30 PM Income Taxation of Nonresident Aliens This presentation will address basic U.S. income tax rules that apply to nonresident aliens, including determining when a person is a U.S. resident for U.S. federal income tax purposes, the kinds of U.S.-source income that are subject to tax in the hands of nonresident aliens, and the effect of income tax treaties on residency issues and substantive income tax issues. 2:20 PM Estate and Gift Taxation of Nonresident Aliens This presentation will cover basic estate, gift, and generation-skipping transfer tax rules that apply to nonresident aliens of the United States who own U.S. situs property, including a discussion of how treaties modify those rules in certain circumstances and estate planning strategies for nonresident aliens with U.S. situs property. 3:25 PM Compliance Initiatives/ Voluntary Disclosure 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. 4:25 PM Developments in Offshore Compliance and Enforcement Review of IRS initiatives to identify taxpayers using offshore accounts and structures to avoid or evade tax, as well as options available to taxpayers who want to voluntarily correct past noncompliance; new developments 5:15 PM Adjournment for the Day 3:10 PM Networking and CLE CREDIT HOURS, INCLUDING 2.0 HOURS OF ETHICS 16.5 CPE CREDIT HOURS IN TAXATION REGISTER ONLINE CLE-NEWS [ ]

6 ADDITIONAL INFORMATION HOTEL ACCOMMODATIONS A limited block of rooms has been reserved at the San Antonio Marriott Riverwalk. Room rate: $215 per night, single or double occupancy. These rooms will be held as a block, unless exhausted, until October 18, at which time they will be released to the general public. Registrants must make their own hotel reservations and indicate that they attending the ALI CLE Modern Real Estate Transactions conference to qualify for rooms in the block. Room reservations may be made by calling San Antonio Marriott Riverwalk, 889 E Market St, San Antonio, TX 78205; (210) or (800) Confirmations will be sent by the hotel. Please read the cancellation policy carefully. STUDY MATERIALS Going green in 2017! Course materials will be available in electronic format for download the week before and during the course. Print materials will not be distributed. All registrants are advised to bring laptops or tablets to the course to view the course materials, including updates. Go to for more info about: Registration/cancellation/requirements for persons with disabilities/scholarships MANDATORY CLE CREDIT ALI CLE programs are accredited in all MCLE jurisdictions. Credit in CO is available by reciprocity; credit in ID, LA, and RI is available upon request. For specific information on CLE, CPE, or other professional accreditation in your state, TeamMCLE@ali-cle.org, go to 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: www. nasbaregistry.org. For information on ALI CLE s complaint and refund policies, call Customer Service at (800) CLE-NEWS. CPE Credit hours for this course: 16.5 in Taxation. 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 ALSO FROM ALI CLE 30 TH ANNUAL ADVANCED COURSE and LIVE VIDEO WEBCAST Employee Benefit Plans Of Tax-Exempt And Governmental Employers Featuring Practical Solutions to Problems under the Internal Revenue Code, ERISA, Other Federal Laws, and State Law Requirements THURSDAY - FRIDAY OCTOBER 5-6, 2017 WASHINGTON PLAZA HOTEL WASHINGTON, DC Register by AUGUST 31, 2017 and SAVE $200. * Enter coupon code CZ009EB2 at checkout.