In today’s uncertain world, more high-net-worth Americans are exploring alternative residency or citizenship options to safeguard their wealth, create new opportunities, and secure their legacy. However, where you hold citizenship doesn’t have to limit where you live. After acquiring a second passport, tax considerations come into play. Should U.S. citizenship (or green card status) be terminated? What are the tax consequences? When considering expatriation, the focus often shifts to navigating the complex income, estate, and gift tax implications. As trusted advisors to clients seeking these alternatives, it's essential to deliver estate planning solutions that are clear, cost-effective, and designed to avoid litigation—ensuring their assets and future are fully protected.

Structuring inbound investments for non-U.S. taxpayers presents a variety of trade-offs that must be carefully balanced such as income tax efficiency, minimizing withholding and filing obligations, producing post-mortem basis adjustment, avoiding anti-deferral regimes, continuation with tax treaties, and local law considerations. The appropriate structure - whether it be a trust, corporate partnership - or a combination, will also be informed by the type of U.S. investment being made, including financial assets, real estate or tangible personal property, such as artwork.

For estate planners, the world seems to be getting smaller as more clients with international interests seek solutions to increasingly complex issues regarding their estate and tax planning matters. In a time of stepped-up tax enforcement, you need to be fully fluent regarding complex U.S. income, estate, and gift tax rules affecting United States clients who own foreign property, who have foreign financial accounts, or who are beneficiaries of foreign trusts, as well as noncitizens who live or invest in the United States, to reduce gift and estate tax exposure.

Reporting and disclosure are the fundamental tools used by governments to enforce their domestic tax laws. In recent years, the U.S. federal laws requiring reporting and disclosure -- including the Corporate Transparency Act of 2022 -- have been dramatically expanded and the civil penalties for failure to comply with such laws have been substantially increased. This session details the numerous tools available to the IRS for obtaining information on U.S. taxpayers’ holdings. It will also review U.S. federal reporting and disclosure obligations applicable to international investment and transactions and the penalties for failure to comply with those obligations.

“Too many American companies go into China or start doing business with Chinese companies, without really knowing the varied risks China poses to their valuable intellectual property and trade secrets,” said Dan Harris, author of the China Law Blog. “These risks should be of utmost concern to anyone whose interests intersect with China. We will show you how to prepare your deals, avoid costly thefts and litigation and defend your IP.”