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