One of the effects of our increasingly global economy is the movement of people and property across borders. For wealthy families whose members may include citizens and residents of multiple countries, the opportunities and challenges of property ownership, asset transfers, and tax compliance reporting can be significant. We have extensive experience in assisting ultra high net worth clients who face the challenges of cross-border estate planning.
Members of our practice work with our clients and their local counsel and advisors in the relevant foreign jurisdictions on many aspects of international and cross-border estate and income tax planning and tax compliance matters, including:
- U.S. inbound wealth transfer planning, including the creation and funding of domestic dynasty trusts, foreign grantor trusts, and assistance in optimizing non-U.S. structures and ownership for U.S. income and wealth transfer tax purposes.
- Compliance matters, including reporting foreign assets, trusts, and the receipt of certain gifts; Foreign Account Tax Compliance Act (FATCA) matters; the Offshore Voluntary Disclosure Program (OVDP); and the preparation of gift and estate tax returns for non-resident, non-citizens.
- Planning for non-U.S. citizen spouses, including the preparation of qualified domestic trusts (QDOTs).
Matters for our clients have included transactions or issues involving Australia, Austria, Canada, the Caribbean, Central America, Colombia, Croatia, France, Germany, India, the United Kingdom, the Philippines, Switzerland, Turkey, and other countries.