A Guide to International Estate Planning: Drafting, Compliance, and Administration Strategies

Front Cover
Jeffrey A. Schoenblum
Section of Real Property, Probate, and Trust Law, American Bar Association, 2000 - Business & Economics - 734 pages
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This resource provides expert and current guidance on the basic principles of international estate planning, the complex taxation issues involved, jurisdictional options, and governmental controls and reporting requirements.

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Contents

Basic Conflict of Laws Principles
3
Chapter 2
21
Returns Required to be Filed by Nonresident Aliens or Persons
39
Chapter 3
47
Formalities of Execution
56
Chapter 4
62
Conclusion
80
Appendix 4AConvention Concerning the International
81
F PreResidency Planning for Grantors
364
Kozusko and Stephen K Vetter
372
Chapter 10
373
Special U S Tax Rules Concerning Tax Avoidance upon
392
Destination Country Considerations
430
Appendix 10BInformation to Be Included in a Ruling Request
436
Appendix 10CInformation Required to Be Provided for Gain
442
Chapter 11
471

Chapter 5
101
Chapter 14
113
Theories of Marital Property on the International Stage
116
The LawDetermining Affiliation
123
Immediate and Secondary Questions
129
Chapter 7
147
Deductions
160
Taxpayer Identification Numbers
164
Tax Treatment of U S Beneficiaries of Grantor Trusts
188
Chapter 8
215
When Is Qualification as a QDOT Determined?Provisions
244
Taxation Of QDOTs
264
Rise to QDOT Tax
272
Death of the Noncitizen Surviving Spouse
280
Effect of Changes in the Federal Gift and Estate Tax Marital
296
Chapter 9
335
PreResidency Planning for U S Income Taxes
349
Convention on the Law Applicable to Succession to
490
Income Tax Treaties
493
Royalties
519
Pensions
526
Trusts and Alternative Vehicles for the International
573
Letters of Wishes and Protectors as Devices to Further
601
The Inheritance and Gift Tax Treatment of AngloAmerican Trusts
614
Considerations Pertaining to Particular
635
Patterns of Death Taxation for Persons Having Contacts
647
Enforcement of CrossBorder Tax Liabilities
653
Advising the Client Who Has Ties With Mexico
658
The Consequences of Different
697
INDEX
705
CONTRIBUTORS
732
Joel J Karp
733
Copyright

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