2021 Annual Estate and Gift Tax Conference: Hot Topics on Dealing with International Taxpayers and Tax

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2021 Annual Estate and Gift Tax Conference: Hot Topics on Dealing with International Taxpayers and Tax

Taxation Section

Credit(s):

2.25 Legal Specialization in Estate Planning; Trust & Probate Law
2.25 Legal Specialization in Taxation Law
2.25 Participatory MCLE Credits

Course Number:

Tax_Estate&Gift_21_01

Original Program Date:

May 28, 2021

Duration:

2 hours 15 minutes

Access:

Available for 3 months after Registration

Passport:

This product is Passport Eligible

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Category: Taxation

Category: Taxation (show less)

The panel will discuss tips and traps for international income and estate tax practitioners when using tax treaties to address an international taxpayer’s federal income, gift and estate tax planning issues. The panel will provide insights on treaty-shopping to maximize an international taxpayer’s US estate tax exemption and use of competent authority mechanism to resolve the “grey areas”, and issues that arise when dealing with Australia, Canada, and the PRC. The panel will also discuss model treaty provisions in US bilateral tax treaties and tax information exchange agreements that are used by tax authorities to request tax return information and tax collection assistance, including frequency of requests for information among tax authorities, the procedure in the U.S. for making requests and processing requests received, grounds and applicable procedures for challenging such requests under United States v. Powell, 379 U.S. 48 (1964), and its progeny, and recent related litigation.

In the first 15 mins of this program hear welcome remarks from Robin Klomparens.

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