Overview
Michael Rosen-Prinz will present “Foreign Trust Tax Planning: The Difficult Questions” at the PLI’s International Estate & Tax Planning 2017 program. He will discuss the practical strategies dealing with:
- Throwback tax
- Double taxation due to application of more than one country’s rules: mismatched timing of income or transfer tax, inconsistent definition of taxpayer, inconsistent sourcing rules, imperfect tax credit rules
- Use and misuse of foreign corporations
- Income shifting
- Mobility, planning for immigration and emigration of settlors and/or beneficiaries and changes in the residency of trustees
- Decanting and migration
- Potpourri of common and not-so-common problematic scenarios facing trustees
- Insurance considerations
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