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Fundamentals of Cross-Border Estate & Gift Tax Planning

FUNDAMENTALS OF CROSS-BORDER ESTATE & GIFT TAX PLANNING

Available Date(s)
Thursday, April 10, 2025: 9:00AM EDT

Cost Free
CPE Credits 2.0 hours
Subject Area 2.0 - Taxes (Federal Tax)
CE Credits 2.0 hours
Course Id# - HURS9-T-01805-25-O
Course Level Basic
Instructional Method Group Internet Based
Prerequisites None
Advanced Preparation None
Course Description

Cross-border estate and gift tax planning presents unique challenges due to varying residency, domicile, and tax treaty considerations. This course provides a comprehensive overview of U.S. estate and gift tax implications for non-resident aliens, resident aliens, and U.S. citizens with foreign assets or beneficiaries. Participants will gain insight into estate tax exemptions, gift tax exclusions, planning strategies for non-citizen spouses, trust structures, and tax-efficient wealth transfer techniques. The session will also cover FIRPTA regulations, Qualified Domestic Trusts (QDOTs), and the impact of tax treaties on cross-border planning.

Learning Objectives

  • Differentiate between residency and domicile for U.S. estate and gift tax purposes and analyze their impact on tax liability

  • Identify key U.S. estate and gift tax exemptions, deductions, and exclusions available to non-resident aliens and resident aliens

  • Evaluate tax planning strategies for non-citizen spouses, including the use of Qualified Domestic Trusts (QDOTs) and marital deduction limitations

  • Outline the implications of FIRPTA on foreign individuals holding U.S. real property and develop strategies for tax-efficient property transfers

  • Describe tax treaty provisions to mitigate double taxation and optimize cross-border wealth transfers

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Matthew E. Rappaport concentrates his practice in Taxation related to Real Estate, Corporations, Partnerships, and Trusts & Estates. He advises clients regarding tax planning and structuring for generational wealth transfer, commercial real estate enterprises, business transactions, and cross-border considerations. He primarily advises real estate professionals, financial professionals, and closely-held business owners. He also functions as a subcontractor for other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise.

Mr. Rappaport graduated from Washington University in St. Louis in 2007, cum laude, with an undergraduate degree in Political Science. His undergraduate thesis was a cross-sectional analysis of the corporate culture of the privately held financial firm Edward Jones. He received his Juris Doctor and Master of Laws in Taxation from Georgetown University Law Center in 2011. Mr. Rappaport is licensed to practice in New York. He is an active member of the Nassau County Bar Association, the New York State Bar Association, and the American Bar Association. He was the Co-Vice Chair of the Tax Committee of the Nassau County Bar Association from June 2015 until June 2016.

He serves on the Sales, Exchanges, and Basis Committee of the American Bar Association Section of Taxation. Mr. Rappaport has authored articles for the Nassau Lawyer, Thomson Reuters’ Journal of Real Estate Taxation, The Tax Adviser, Bloomberg BNA’s Tax Management – Real Estate Journal, and the Journal of Taxation of Investments. He has spoken at the request of the American Bar Association, the National Conference of CPA Practitioners, the Financial Planning Association, Strafford Publications, the School of Accounting at LIU Post, and a wide variety of law, accounting, and wealth advisory firms. He is a founder of the young professionals networking group Hydra Collective.

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Priya Prakash Royal, Esq., LL.M., MBA, AEP, TEP practices in international taxation, cross-border trusts and estates, and multinational private client practice. With a distinguished career that began in 2006, she has also served as an Estate Tax Attorney at the IRS, where she audited billionaire estate and gift transfers. Priya is admitted to practice in the District of Columbia, New York, New Jersey, Pennsylvania, and Maryland.

Priya’s focus includes tax strategy, charitable planning, multinational estate and asset protection planning, and digital-era compliance. She holds the TEP (Trusts & Estate Practitioner – International) and AEP (Accredited Estate Planner) designations, which reflect her high standards in the field.

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About Our Presenter

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Matthew E. Rappaport concentrates his practice in Taxation as it relates to Real Estate, Corporations, Partnerships, and Trusts & Estates. He advises clients regarding tax planning and structuring for generational wealth transfer, commercial real estate enterprises, business transactions, and cross-border considerations. He primarily advises real estate professionals, financial professionals, and closely held business owners. He also functions like a subcontractor for other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise.