PLI’s International Estate & Tax Planning 2017


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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