International Estate & Tax Planning Conference
Dina Kapur Sanna will be speaking on two panels at International Estate & Tax Planning 2019, a conference presented by the Practising Law Institute and held in New York, NY. The first panel, "Structuring Investment in U.S. Real Property by Nonresident Aliens (NRAs)," will discuss various types of taxation of NRAs compared to U.S. citizens and residents as well as the different tax structures available to NRAs to hold U.S. real property. The second panel, "Foreign Trusts and U.S. Beneficiaries," will address how to determine whether an arrangement is classified as trust, residency rules for trusts and how to qualify NRA grantor as the tax owner of a trust under section 671, rules for the taxation of and reporting by U.S. beneficiaries of a foreign trust, and how holding companies can be used to achieve a tax-free step-up in basis and techniques to avoid anti-deferral rules.