Presented by the Taxation Section. Earn 5.0 Hours of MCLE, which includes Legal Specialization in Taxation Law and Estate Planning, Trusts and Probate Law.

Opening Remarks

9:00 AM – 9:15 AM

Opening remarks by Robin Klomparens (robin@wkblaw.com)

Panel 1: Hot Topics on Dealing with International Taxpayers and Tax Treaties

9:15 AM – 11:15 AM

The panel will discuss tips and traps for international income and estate tax practitioners when using tax treaties to address an international taxpayer’s federal income, gift and estate tax planning issues. The panel will provide insights on treaty-shopping to maximize an international taxpayer’s US estate tax exemption and use of competent authority mechanism to resolve the “grey areas”, and issues that arise when dealing with Australia, Canada, and the PRC. The panel will also discuss model treaty provisions in US bilateral tax treaties and tax information exchange agreements that are used by tax authorities to request tax return information and tax collection assistance, including frequency of requests for information among tax authorities, the procedure in the U.S. for making requests and processing requests received, grounds and applicable procedures for challenging such requests under United States v. Powell, 379 U.S. 48 (1964), and its progeny, and recent related litigation. 

Speakers:           

• Caroline Ciraolo, cciraolo@kflaw.com
• Marsha Dungog, marsha.dungog@withersworldwide.com
• Kurt Kawafuchi, kkawafuchi@aol.com

Panel 2: Estate Planning for 2021

11:30 AM – 12:30 PM

As the speaker says this can be summarized by paraphrasing Michael Corleone in The Godfather III – when 2020 ended, and you think that you’re finished with estate plans designed to maximize the use of your clients’ exclusion amount, here’s 2021 and it’s “pulling you back in.”  This presentation will provide an overview of the results of the 2020 and 2021 elections, the Biden proposals, the potential for legislative retroactivity and some obvious – and not-so-obvious – planning techniques to consider.  

Speaker: George D. Karibjanian, gkaribjanian@fkl-law.com

Panel 3: Governing Strategies and How and Why We Use Them 

1:00 PM – 2:00 PM

The more you work with very high-end clients, the more you realize that plans relying on a few of trusts that call for distributions based on the ascertainable standards of health, education, maintenance, and support fall far short of what these clients need. Clients whose plans involve operating businesses, significant family philanthropy, or more complex situations that amount to family enterprises will benefit from family governance planning. This session will explore how using governance strategies such as mission statements, family constitutions, family assemblies and meetings, and shareholders agreements and family councils, can enhance a family’s overall estate plan.

Speakers:          

• Andrea L. Kushner, andrea.kushner@bernstein.com
• Mark Powell, Mark.Powell@hklaw.com

Panel 4: What Every Planner Needs to Know After Prop 19

2:00 PM – 3:00 PM

The speaker will discuss Prop 19 and the current property tax rules.  The speaker will also cover the rules related to entities as well as what strategies remain for property tax planning.  

Speaker: Bradley R. Marsh, marshb@gtlaw.com