IBA Annual Conference Miami 2022
30 Oct - 4 Nov 2022
Room 210, Level 2
Coming and going part 1: hello America - what the well-advised immigrant needs to know and do before they arrive
Tuesday 1 November (0930 - 1045)
Private Client Tax Committee
This panel will cover the various tax and non-tax considerations that individuals should consider before becoming a US income tax resident. The panel will primarily focus on pre-immigration planning to mitigate exposure to US income and estate tax, including: stepping up the client’s basis in assets prior to residency, addressing the impact of the various US anti-deferral regimes, creating income tax advantaged structures, and protecting assets from US estate and gift tax. Panelists will also provide an overview of the technical rules on US tax income, gift and estate tax residency. Further, the panelists, which consist of private client attorneys from around the world, will analyze how to coordinate US pre-immigration planning with the relevant tax and succession regimes in the client’s home jurisdiction.