International Estate Planning

Our lawyers coordinate global estate planning for U.S., foreign and multinational families. Many of our U.S. clients have assets abroad, and we coordinate their estate planning with local counsel in those jurisdictions. We also represent foreign clients with U.S. business interests and/or family members in the United States. We assist these clients in structuring their U.S. investments to maximize U.S. tax advantages and advise them on tax-efficient methods of transferring those investments to succeeding generations. We also advise individuals on pre-U.S. residency tax planning and on the U.S. tax aspects of renouncing citizenship or long-term permanent resident status.

We administer estates of non-U.S. residents who die owning property in the United States, with particular emphasis on property subject to U.S. estate tax, including probate and the preparation and filing of U.S. (and state, where necessary) estate tax returns.

Recent representations include:

• Advice to a long-term permanent resident on the U.S. tax implications of relinquishing his “green card” upon his return to Switzerland;
• Representation of a Mexican individual in creating a tax-compliant structure to invest in a European company, and advising him in connection with the shareholder agreements and other documentation for the investment;
• Advice on the restructuring of a Liechtenstein entity into a common law trust for a Colombian client whose children had become U.S. residents, in order to avoid disadvantageous U.S. tax implications for the children;
• Representation of Venezuelan individuals in (i) creating structures for their non-Venezuelan investments which are tax-compliant in Venezuela, while at the same time reducing or eliminating their exposure to U.S. estate taxes, and (ii) creating trusts and other estate planning vehicles to provide for the transfer of such assets to succeeding generations;
• Advice to a U.S. citizen owning real estate in France as to the use of separate U.S. and French Wills to dispose of property in each jurisdiction, and coordination of the drafting of the Wills with French counsel;
• Preparation and filing of a U.S. estate tax return for an Irish citizen who owned common shares of U.S. publicly-traded companies, and arranging for the tax to be paid and the assets to be released to the beneficiaries;
• Advice to a U.S. citizen resident in the United Kingdom on the application of the U.S./UK estate tax treaty, in coordination with counsel in London; and
• Representation of an extended South American family on the restructure of its trusts and holding companies to minimize U.S. estate and income tax for the family members who have become U.S. citizens or residents.