US Tax Considerations for Non-Residents
Author: Ernest Marais
Service: Andersen Tax
This webinar looks at US estate and gift tax issues and structuring trusts where the parents are not US citizens or residents. Focus topics are:
- US Estate Tax applicable to Non-Residents;
- Taxation of Foreign Trusts (Non-US Trusts) with US beneficiaries;
15 June @ 3pm CAT
US estate and gift taxation applicable to non-residents
This session will focus on the US estate and gift tax issues (together, transfer taxes) that pertain to non-residents of the US. The US transfer tax applies to non-residents who transfer US property to family (or others) within or without the US at a federal rate of 40% with little exemption. It will cover US real estate, stock/partnership interests with US situs, as well as other common situations. Planning will include use of foreign companies, foreign trusts and other methods to reduce or eliminate US taxation. Also covered will be how to structure gifts/inheritances of non US assets to US beneficiaries to avoid future US taxes.
Taxation of foreign trusts with US beneficiaries
This session will focus on structuring trusts where the parents are not US citizens/residents but have children or other family who are either US citizens or residents. It will cover lifetime strategies using trusts as well as testamentary structuring. It will include the income tax consequences of the trust during the Settlors life as well as after death. The accumulation distribution penalty regime will be discussed as well as ways to avoid it, domestication of the trust and other common fact patterns.
Speakers: David Roberts, New York and Joseph Toce, New York and Connecticut
Moderator: Ernest Marais, Johannesburg