international trust and estate planning - cle programs · american law institute continuing legal...

International Trust and Estate PlanningTHURSDAY-FRIDAYOCTOBER 27-28, 2016WASHINGTON, D.C. WASHINGTON PLAZA HOTEL

American Law InstituteC O N T I N U I N G L E G A L E D U C A T I O N

R E G I S T E R O N L I N Ew w w . a l i - c l e . o r g / C Y 0 0 7

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

REGISTER BY AUGUST 31 AND

SAVE $300*

OR ADDITIONAL REGISTRANTS

SAVE 50%* S E E B A C K F O RD E TA I L S

32ND ANNUAL ADVANCED COURSE

and LIVE VIDEO WEBCAST

’s cr

“The

13.25 C L E C R E D I T H O U R S , I N C L U D I N G

2.0 H O U R S O F E T H I C S

15.5 C P E C R E D I T H O U R S I NT A X A T I O N

limite

r of f

n “Sc

ps.”

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

INTERNATIONAL TRUST AND ESTATE PLANNING

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 always-changing area. New and updated discussions address the full range of issues confronting international tax planning practitioners, including compliance with the OECD’s Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA), among many others.

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 noncitizensliving 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.

Other topics, new or updated for 2016, 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

• Foreign Account Tax Compliance Act (FATCA) compliance issues

• 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 most pressing questions and network with faculty members and colleagues from around the world.

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.

REGISTER TWO OR MORE AND SAVE!

Register one person to attend this course in-person at full price and get all subsequent in-person registrations for this course from your organization at 50% o� ! Call 1-800-CLE NEWS (253- 6397). Discounts may not be combined.

HOTEL ACCOMMODATIONS

A limited block of rooms has been reserved at the Washington Plaza Hotel. Room rate: $259 per night, single or double occupancy. These rooms will be held as a block, unless exhausted, until September 26, 2016, 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 program to qualify for rooms in the block.

Room reservations may be made by calling the Washington Plaza Hotel, 10 Thomas Circle, NW, Washington, D.C. 20005; phone (202) 842-1300; or online at https://www.reservations-page.com/C00519/H11149/be.ashx?pc=H7QW. Con� rmations will be sent by the hotel. Please read the hotel cancellation policy carefully.

COURSE MATERIALS

Registrants have the option of receiving their study material on a USB drive or as a printed course. Print materials can be voluminous, so the USB option is recommended. Be sure to indicate your preference when you register. Go Green! Select the USB option!

Go to www.ali-cle.org/CY007 for more info about:Registration/cancellation/requirements for persons with disabilities/scholarships

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 26 states, Canada, and the U.K.!

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 13.25 credits, including 2 ethics credits, in 60-minute MCLE jurisdictions; and for 16 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 speci� c information on CLE, CPE, or other professional accreditation in your state, please e-mail the MCLE Team at [email protected], go to http://www.ali-cle.org/mcle, or call 1-800-CLE-NEWS.

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 � nal 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.learningmarket.org. 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: 15.5 in Taxation (live group and group internet-based programs). Learning Objectives: Acquisition of knowledge and skills to develop pro� ciency as a practitioner; maintenance of professional competence as a practitioner. Suggested Prerequisite: Experience in practice in subject matter. Level of Instruction: Advanced.

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’re a

sophisticated professional looking to expand your practice), you must attend this program!

ADDITIONAL INFORMATION

“Very good range of topics…� e interactive format with

input from panel members and questions from audience during

talks made it more engaging and dynamic.”

P R O G R A MF o r f u l l p r o g r a m d e t a i l s , p l e a s e v i s i t

w w w . a l i - c l e . o r g / C Y 0 0 7

“� is course – from the presentations, the materials, and the conversations with practitioners – is the absolute

best CLE program in the country.”

3:30 PM Ethical Issues in Offshore Planning(with Ethics Roundtable)

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.; limits on "bank secrecy" and practical lessons of dealing with increasingly complex tax and regulatory regimes

5:30 PM Adjournment for the Day

O c tob er 2 8 , 2 0 1 6

8:00 AM Continental Breakfast and Networking Session

V I D E O W E B C A S T S E G M E N T C

8:30 AM Recap of Day One– Messrs. Moore and Pfeifer

8:45 AM Estate Planning for Nonresident Aliens

"Domicile" as the basis of taxation; substantive gift, estate, and GST tax rules; planning for NRAs with U.S. situs property; use of estate and gift tax treaties

9:35 AM Developments in International Philanthropy

New options for international charitable planning in the PATH Act of 2015; current IRS focus on charitable conduits for foreign organizations; minimizing U.S. taxes on foreign tax-exempts; FATCA issues for nonpro� ts; special rules for charitable trusts; traps for the unwary

10:25 AM Networking and Refreshment Break

10:40 AM Immigration and Related Planning

Immigration planning for high net worth clients; common non-immigrant (temporary) visas; investment-based options for obtaining permanent resident (green card) status; obtaining and terminating U.S. citizenship

O c tob er 2 7 , 2 0 1 6

7:45 AM Registration and Continental Breakfast

8:50 AM Administrative Remarks – ALI CLE Staff

V I D E O W E B C A S T S E G M E N T A

8:55 AM Opening Remarks and Course Overview – Messrs. Moore and Pfeifer

9:00 AM Inbound Planning with Foreign Trusts (Including Planning for Underlying Foreign Companies)

U.S. taxation of foreign grantor trust and foreign non-grantor trust structures both at the trust level and the bene� ciary level, including reporting-related issues; 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

10:45 AM Trusts and Alternative

Vehicles

U.S. tax de� nition 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; e� ect of the Hague Convention

11:35 AM Trust and Tax Law Developments Outside the U.S.

Important developments and trends in o� shore � nancial centers that a� ect U.S. advisers who have clients with foreign property and � nancial accounts and interests in foreign trusts, including developments in Switzerland

12:25 p.m. Lunch for Registrants and Faculty (provided by ALI CLE)

V I D E O W E B C A S T S E G M E N T B

1:40 PM 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 � nancial accounts

2:30 PM Networking and Refreshment Break

2:45 PM Practical Advice for Clients with Foreign Trusts and Foreign Business Interests

What are the relevant issues when there is a "foreign trust" in an investment structure? What are the potential tax consequences to the settlor, bene� ciaries and trustee? What is the interplay of the foreign trust and CFC and PFIC rules and how can clients use pass-through entities in this situation? What records should be maintained and for how long? What reporting is potentially required for foreign trusts and underlying foreign corporations?

11:30 AM Expatriation

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; practical issues with advising citizens and long-term residents

12:20 PM Lunch Break(on your own)

V I D E O W E B C A S T S E G M E N T D

1:40 PM CRS, FATCA, and

Beneficial Ownership Information Exchange

Trends in the law and the latestdevelopments in automatic exchange of tax information, including FATCA and the Common Reporting Standard (CRS), as well as transparency in bene� cial ownership, and how these fast-changing rules a� ect clients with cross-border investments, entities, and properties

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

M. Read MooreMcDermott Will & Emery LLP

Michael G. PfeiferCaplin & Drysdale, Chartered

Faculty

Planning Chairs (also on faculty)

Mark John BarmesLenz & Staehelin

Henry Christensen IIIMcDermott Will & Emery LLP

Michael W. DurhamKirton McConkie PC

Ellen K. HarrisonMcDermott Will & Emery LLP, ALI Member

Mark E. MatthewsCaplin & Drysdale, Chartered

Carlyn S. McCa� reyMcDermott Will & Emery LLP

John C. McDougalCounsel, Small Business/Self-Employed Division, Internal Revenue Service ‡

Michael J. MillerRoberts & Holland LLP

John RichesRMW Law London

Dina Kapur SannaDay Pitney LLP

John M. StaplesErnst & Young LLP

Stephen C. TrowTrow & Rahal, P.C.

Bruce ZagarisBerliner, Corcoran & Rowe, LLP

ALI CLE Program Sta� :Robert Rushton ([email protected])

‡ Invited

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

“Fourth time attending. Course great as always.”

A L L T I M E S E A S T E R N

“I particularly enjoyed the ‘cur-rent development’ portions of the presenters’ talks…� is was

a nearly perfect course.”

4:15 PM Offshore Voluntary Disclosure Program (OVDP) and Other Initiatives

Review of IRS initiatives to identify taxpayers using o� shore accounts and structures to avoid or evade tax, as well as options available totaxpayers who want to voluntarily correct past noncompliance; new developments

5:05 PM Questions and Answers

5:15 PM Adjournment

w w w . a l i - c l e . o r g / C Y 0 0 7

O c tob er 2 8 , 2 0 1 6

O c tob er 2 7 , 2 0 1 6

Vehicles

Faculty

‡ Invited

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

5:15 PM Adjournment

w w w . a l i - c l e . o r g / C Y 0 0 7

O c tob er 2 8 , 2 0 1 6

O c tob er 2 7 , 2 0 1 6

Vehicles

Faculty

‡ Invited

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

5:15 PM Adjournment

w w w . a l i - c l e . o r g / C Y 0 0 7

O c tob er 2 8 , 2 0 1 6

O c tob er 2 7 , 2 0 1 6

Vehicles

Faculty

‡ Invited

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

5:15 PM Adjournment

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

SAVE $300*

’s cr

“The

limite

r of f

n “Sc

ps.”

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

COURSE MATERIALS

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

SAVE $300*

’s cr

“The

limite

r of f

n “Sc

ps.”

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

COURSE MATERIALS

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

SAVE $300*

’s cr

“The

limite

r of f

n “Sc

ps.”

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

COURSE MATERIALS

international trust and estate planning - cle programs · american law institute continuing legal...

Documents