This course provides legal professionals with in-depth, hands-on training on U.S. estate and gift tax rules as they apply to non-resident aliens (NRAs). NRAs face a unique set of rules and exposures in the U.S. transfer tax system, especially when owning U.S. situs assets, gifting to U.S. persons, or planning intergenerational transfers involving U.S. beneficiaries. The course focuses on legal strategy, tax compliance, cross-border planning, and structure optimization, equipping practitioners with the tools to advise international clients and corporate fiduciaries.
Participants will engage in legal scenario modeling, tax form preparation, treaty application, and design of trust and holding structures. Real-life case simulations will enhance skills in identifying U.S. tax exposure, navigating IRS filing obligations, and defending compliance strategies in audits or voluntary disclosures.
Course Objectives
By the end of this course, participants will be able to:
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Identify what constitutes U.S. situs property subject to estate and gift tax for NRAs.
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Differentiate between U.S. citizen/resident and non-resident alien transfer tax regimes.
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Calculate tax exposure and apply the appropriate exemptions and treaty protections.
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Advise on structuring cross-border estates, trusts, and inter vivos gifts.
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Prepare IRS Forms 706-NA and 709 for NRA clients.
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Implement tax-efficient wealth transfers involving U.S. beneficiaries.
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Manage IRS scrutiny, penalties, and legal documentation for compliance.
