Estate planners are increasingly working with expatriates and foreigners regarding their estate and tax planning for their U.S.-owned businesses and investments. This seminar will discuss the specific issues of inbound and outbound estate and gift tax planning, as well as, the compliance obligations of imposed on both clients and practitioners engaging in foreign estate plans.  Finally, this seminar will discuss the IRS recent audit campaigns targeting foreign investment in the U.S. and what relief provisions are available if you or your client need to come into compliance with information reporting obligations.You Will Learn:

• How to determine U.S. tax residence for the Estate and Gift Tax
• Foreign information reporting for foreign gifts and foreign transfers to and distributions from foreign trusts
• Substantive U.S. estate and gift tax rules relative to foreign investors’ planning and tax minimization alternatives including the use of foreign trusts, determining the gross estate and taxable gifts, and modifications to the unified credit and marital deduction
• How to protect your client from increased IRS audit activities in U.S. estate and gift tax areas as they relate to foreign investors
• Pre-immigration planning to reduce exposure to estate and gift taxes
• Possible relief from foreign gift and trust reporting compliance through recently revised voluntary disclosure programs