New York Partner, Dina Kapur Sanna Co-Chair of International Trusts & Estates Webinar Using Trusts and Alternative Vehicles for Inbound Investments

On April 4, Trusts and Estates Partner Dina Kapur Sanna co-chaired an American Law Institute Continuing Legal Education webinar on Using Trusts and Alternative Vehicles for Inbound Investments. Topics included in the discussion were based around structuring inbound investments for non-U.S. taxpayers presents a variety of trade-offs that must be carefully balanced such as income tax efficiency, minimizing withholding and filing obligations, producing post-mortem basis adjustment, avoiding anti-deferral regimes, continuation with tax treaties, and local law considerations.

The appropriate structure - whether it be a trust, corporate partnership - or a combination, will also be informed by the type of U.S. investment being made, including financial assets, real estate or tangible personal property, such as artwork. The panel took a comprehensive look at the fundamental and advanced issues that arise when structuring U.S. inbound investments by international clients, including:

• U.S. income taxation of foreign trusts, corporations and partnerships
• Estate tax-efficient structuring of foreign entities
• Single and multiple-tier entity and trust structures
• Planning for basis step up for nonresident aliens
• Investments involving two-tiered corporations and partnerships
• Additional considerations of complex investment and family office structures
• Hybrid residency issues