This treatise provides in-depth analysis and guidance on U.S. income and wealth transfer taxes affecting cross-border planning; foreign death taxes; planning techniques for the U.S. estate, gift and generation-skipping transfer taxes; coverage of cross-border planning issues; the impact of U.S. estate and gift tax treaties; expatriation; cross-border charitable planning; transnational entity structuring in third countries; marital planning; pre-immigration planning; conflict of law issues; forced heirship statutes; the use of domestic and offshore trusts; asset protection; and U.S. information reporting requirements.

Broad topics include:

• Planning for U.S. citizens and residents with foreign-based assets
• Planning for foreign nationals with U.S. based assets
• Inheritance and marital planning for cross-border families
• Income tax planning for U.S. expatriates
• U.S. Social Security considerations
• Foreign client investment in U.S. real estate, including FIRPTA
• U.S. tax rules governing foreign grantor and nongrantor trusts, foreign estates, and foreign beneficiaries of U.S. trusts and estates
• Defining “resident” status for U.S. estate tax purposes and how it differs from “resident” status for U.S. income tax purposes
• Use of lifetime gift tax planning techniques in cross-border planning, including GRATs and other split interest transfers, powers of appointment, and discounting strategies
• Gift and estate tax planning with noncitizen spouses
• Pre-residency planning
• U.S. income and transfer tax planning for nonresident aliens
• Designing and drafting an effective and compliant asset protection trust
• Selection criteria and discussion of leading asset protection trust jurisdictions
• Expatriation from the U.S.