Going to Combat for Your International Client: Avoiding Landmines and Other Hot Topics in 2012/2013

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1 Going to Combat for Your International Client: Avoiding Landmines and Other Hot Topics in 2012/2013 Presented to the Washington DC Estate Planning Council November 27, 2012 The City Club of Washington Leigh-Alexandra Basha, Esq. Holland & Knight LLP 1600 Tysons Boulevard, Suite 700 McLean, Virginia

2 I Exclusion and Reporting Thresholds II. Offshore Voluntary Disclosure III. Foreign Account Tax Compliance Act (FATCA) IV. Landmines 2

3 I. Exclusion and Reporting Thresholds Annual Exclusion $13,000 $14,000 Marital annual exclusion to a non U.S. citizen spouse Applicable exclusion amount for U.S. citizens/domiciliaries Applicable exclusion amount for non U.S. citizens/non domiciliaries Form 3520 filing thresholds for gifts received from NRAs Form 3520 filing thresholds for gifts received from foreign companies Income tax liability threshold for covered expatriates $139,000 $143,000 $5.12 million $1 million $60,000 $60,000 $100,000 $100,000 $14,723 $15,102 $151,000 $155,000 Exit tax gain exemption amount $651,000 $668,000 3

4 II. Offshore Voluntary Disclosure 4

5 III. FATCA Hiring Incentives to Restore Employment (HIRE) Act March 18, 2010 Added Chapter 4 to Internal Revenue Code Sections Reporting by U.S. taxpayers holding foreign financial assets Reporting by foreign financial institutions 5

6 III. FATCA Key Dates New Individual & Entity Account Preexisting Accounts of Prima Facie FFIs Preexisting Accounts of Entities other than Prime Facie FFIs Preexisting High Value Accounts of Individuals Preexisting Accounts of Individuals other than High Value Accounts Withholding Agents other than Participating FFIs & Deemed- Compliance FFIs By January 1, 2014 By June 30, 2014 By December 31, 2015 N/A N/A Withholding Agents that are Participating FFIs By later of January 1, 2014 OR Effective date of FFI agreement By later of June 30, 2014 OR 6 months after effective date of FFI agreement By later of December 31, 2015 OR 2 years after effective date of FFI agreement By later of December 31, 2014 OR 1 year after effective date of FFI agreement By later of December 31, 2015 OR 2 years after effective date of FFI agreement Withholding Agents that are Registered Deemed- Compliant FFIs By later of January 1, 2014 OR Date of registration N/A N/A N/A N/A 6

7 III. FATCA Intergovernmental Agreements Completed IGA United Kingdom 09/12/2012 Denmark 11/15/2012 "Finalizing" an IGA France Germany Italy Spain Japan Switzerland Canada Finland Guernsey Ireland Isle of Man Jersey Mexico Netherlands Norway Actively engaged in a dialogue Argentina Australia Belgium Cayman Islands Cyprus Estonia Hungary Israel Liechtenstein Malaysia Malta New Zealand Slovak Republic Singapore South Korea Sweden Discussing options Bermuda Brazil British Virgin Islands Chile Czech Republic Gibraltar India Lebanon Luxembourg Romania Russia Seychelles Saint Maarten Slovenia South Africa 7

8 III. Form 8938 Reporting Thresholds Aggregate value of all specified foreign financial assets on December 31 is more than: Or, at any time during the year is more than: Unmarried taxpayers living in the U.S. $50,000 $75,000 Married taxpayers filing a joint income tax return and living in the U.S. Married taxpayers filing separate income tax returns and living in the U.S. $100,000 $150,000 $50,000 $75,000 Unmarried taxpayers living abroad $200,000 $300,000 Married taxpayers living abroad $400,000 $600,000 8

9 III. FATCA (continued) Uncompensated Use of Foreign Trust Property Filing PFIC Form Even Without a Distribution 9

10 Landmine #1: Naming a nonresident alien as trustee, successor trustee or trust protector. Rule: Thus, even if you prepare a trust for a U.S. citizen, always ask for the nationality and residency of all back up trustees, co-trustees, successor trustees and trust protectors. 10

11 Landmine #2: Overlooking the 65-day Election Rule: For all foreign non-grantor trusts, tickler the 65-day deadline. 11

12 Landmine #3: Establishing a U.S. revocable trust with U.S. trustees who then move to the UK. Rule: Always confirm the residency of the trustees and successor trustees even if they are U.S. citizens. Warn your clients to advise you if they move overseas, even if temporarily. 12

13 Landmine #4: Setting up a trust where there is any connection to France. Rule: Avoid having trusts with any French connection, or proceed with great caution. 13

14 Landmine #5: Setting up a trust that makes distributions to a resident of Germany or Spain. Rule: Request your clients to notify you if a beneficiary changes residency. 14

15 Landmines #6: Failing to consider forced heirship rules and failing to take into account foreign tax ramifications of the tax clause in wills and trusts. Rule: Carefully consider whether your client's estate may be exposed to forced heirship claims which could disrupt the estate plan. Also, make sure you consider the tax clause in case an heir (even with a no contest clause) asserts a forced heirship claim in a foreign country. 15

16 Landmine #7: Using a standard pour over will with revocable trust when the client has any foreign assets. Rule: Always engage foreign counsel when a client has a foreign asset. Generally, a trust may not be an appropriate vehicle in certain countries. 16

17 Landmine #8: Failing to consider the citizenship of your client. Rule: If your client has any connection to a foreign country, engage foreign counsel to advise on nontax ramifications. 17

18 Landmine #9: Failing to pay attention to a nonresident alien client's investments. Rule: If your NRA client is concerned about the U.S. estate tax exposure, structure the NRA's investments into non U.S. situs assets. 18

19 Landmine #10: Ignoring the provisions of a treaty. Rule: When advising clients with any foreign connection, check the provisions of any applicable treaty. 19

20 Landmine #11: Making a gift from a NRA in the U.S. Rule: Structure gifts from an NRA outside the U.S., i.e., from the NRA's foreign bank account to the donee's foreign bank account. Note: for an alternative, have the NRA gift stock in U.S. brokerage account. 20

21 Landmine #12: Failing to understand the reporting thresholds for gifts from non U.S. persons. Rule: Advise your client who receives gifts from foreign donors to be aware of their potential reporting obligations. 21

22 Landmine #13: Failing to recognize that a distribution from a foreign trust requires the filing of a Form 3520 or it will incur a 35% penalty on the amount of the distribution. Rule: Since a revocable trust drafted under U.S. law, can still be a foreign trust, care must be taken to report distributions to a U.S. person, even a spouse. 22

23 Landmine #14: Failing to quickly take action with respect to a U.S. person's inheritance of foreign entities after a foreign individual dies. Rule: If your client mentions he or she is receiving a foreign inheritance, immediately tickler 75 days and review the assets in the estate. 23

24 Landmine #15: Failing to prohibit U.S. beneficiaries under a trust if a U.S. person wishes to transfer assets irrevocably to a foreign trust. Rule: If the goal of the client is to irrevocably transfer assets to a foreign trust, draft to exclude U.S. persons as beneficiaries. 24

25 Landmine #16: Assuming that once a green card holder holds his green card for more than 8 out of 15 years, he should apply for U.S. citizenship since he will be subject to the U.S. exit tax under IRC 877A. Rule: It may be better to give up a green card than citizenship. So, if there is any chance the client may consider leaving the US, he may not want to go forward with citizenship without first evaluating the effect it may have on his basis for exit tax purposes. 25

26 Landmine #17: Failing to ask whether an inheritance is from a "covered expatriate". Rule: Always ask your client if he expects a gift or inheritance from an expatriating individual. 26

27 Landmine #18: Making a treaty tie breaker election when client is a long term green card holder. Rule: if a U.S. green card holder is living in a high tax jurisdiction, it is generally better to take the normal foreign tax credit and not make a treaty tie breaker election in order to avoid inadvertently triggering the "exit tax." 27

28 Landmine #19: Retitling assets when one spouse is a non U.S. citizen and failing to trace contributions. Rule: Be careful to trace all assets before changing title when one spouse is a non U.S. citizen. 28

29 Landmine #20: Failing to consider the effects of a community property regime. Rule: Always confirm a couple's marital regime and consider all the ramifications. 29

30 Landmine #21: Failing to analyze potential tax issues when making a split gift election when one spouse is a non U.S. citizen Rule: when one spouse is a non U.S. citizen and the couple is making a split gift election, be cautious especially for gifts to trusts where the NRA spouse is a beneficiary. 30

31 Conclusion 31

32 Contact Information Leigh-Alexandra Basha Holland & Knight LLP 1600 Tysons Boulevard Suite 700 McLean, Virginia Phone: (703) Fax: (703)

33 To ensure compliance with Treasury Regulations (31 CFR Part 10, 10.35), we inform you that any tax advice contained in this correspondence was not intended or written by us to be used, and can not be used by you or anyone else, for the purpose of avoiding penalties imposed by the Internal Revenue Code. If you desire a formal opinion on a particular tax matter for the purpose of avoiding the imposition of any penalties, we will discuss the further Treasury requirements that must be met and whether it is possible to meet those requirements under the circumstances, as well as the anticipated time and additional fees involved. 33

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