Description
Many U.S. citizens and permanent residents have non-U.S. spouses or family members or property interests abroad; likewise, many non-U.S. citizens/non-U.S. residents have U.S. property interests or U.S. family members. Under current U.S. tax law, estate planning can create some specific complications for international families; however, more issues are presented by the OBBB.
U.S. tax rules for estate, gift, and generation-skipping transfer taxes may offer gift planning opportunities. In contrast, some rules for the income taxation of corporations and partnerships may impact how investments are structured. Also, holding business and investment assets through foreign corporations may subject U.S. shareholders to additional tax liability.
On May 22, 2025, the U.S. House of Representatives passed the OBBB, which includes extensions and expansions to the 2017 Tax Cuts and Jobs Act, as well as other provisions that impact estate and income tax planning.
Estate planning for international families must consider which countries' laws govern the disposition of assets, as well as the income, estate, and gift tax treatment of specific transactions, including the interaction of multiple tax regimes in light of pending U.S. tax reform.
Listen as our experienced panel guides attendees on how to plan the estates of clients with interests in foreign business entities, real estate, and financial accounts in light of pending U.S. tax reform. The panel will cover the legal and tax considerations when planning for the disposition of each type of asset and the implications of U.S. tax law.
Presented By
Bio for Annie Attorney; loves horses and arguments
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
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Date + Time
- event
Thursday, October 16, 2025
- schedule
1:00 p.m. ET./10:00 a.m. PT
I. Implications of the OBBB on international estate planning
II. Estate planning tax and legal issues for business interests in the international context
A. Corporations
B. Debt instruments
C. Intangibles
D. Partnerships and LLCs
E. CFC rules
III. Wealth planning: gifts, bequests, and trusts for U.S. clients with assets abroad/non-U.S. clients with U.S. assets
A. Gifts of money
B. Dynasty trusts
C. Foreign grantor trust rules
D. Non-grantor trust rules
E. Real estate
The panel will review these and other key issues:
- Impact of the OBBB on international estate and tax planning
- Potential legal and tax pitfalls when planning for the disposition of a U.S. client's financial and real property interests abroad and a non-U.S. client's interests in the U.S.
- The impact of situs rules on gifts and bequests by non-U.S. citizens/non-U.S. residents, including the disposition of interests in real property, business entities, and debt instruments, and issues involved in converting assets to "intangible" interests
- U.S. tax reporting and compliance issues relating to the disposition of interests in business entities, real property, and financial accounts in the international context
- Benefits and pitfalls of U.S. or foreign grantor or non-grantor trusts for cross-border estate planning, including potential uses of "dynasty" trusts
Learning Objectives
After completing this course, you will be able to:
- Understand key tax provisions of the OBBB on international estate and tax planning
- Identify tax pitfalls when planning for the disposition of a U.S. client's financial and property interests abroad and a non-U.S. client's interests in the U.S.
- Recognize the impact of situs rules on gifts and bequests by non-U.S. citizens/non-U.S. residents
- Understand the U.S. tax reporting and compliance requirements for the disposition of interests in business entities, real property, and financial accounts in the international context
- Recognize the benefits and pitfalls of U.S. or foreign grantor or non-grantor trusts for cross-border estate planning
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of estate, gift and trust taxation including various trusts types, the unified credit, and portability.
BARBRI 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 Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
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