International Estate Planning for Individuals
Serving Residents of Washington DC, Miami, Dallas & Orlando
For non-U.S. citizens that are residing in the U.S.,
estate planning is a multidisciplinary practice that requires knowledge of a multitude
of practices, including:
- International tax
- Gift and estate tax treaties
- International conflict of laws principles
- Foreign tax law
- Foreign forced heirship laws
- Foreign estate planning law
For the unseasoned domestic estate planning attorney, international estates
can be treacherous and are fraught with potential malpractice liability
concerns. Allow Castro & Co. to assist you -- we serve clients worldwide
with office located in Washington DC, Miami, Dallas and Orlando.
U.S. citizens and residents are subject to the U.S. gift, estate, and generation-skipping
transfer (GST) taxes on their worldwide estate. However, for U.S. gift
and estate tax purposes, residency is defined much differently than it
is for U.S. income tax purposes. Unlike the objective standards for U.S.
income tax purposes, residence is more akin to domicile for U.S. gift
and estate tax purposes. This difference gives rise to valuable estate
planning opportunities that clients need to fully utilize.
For example, with proper domicile planning, a non-U.S. citizen individual
can be a U.S. green card holder and resident for U.S. income tax purposes
yet, for U.S. estate tax purposes, be considered a non-U.S. domiciliary
not subject to U.S. gift and estate taxes. This would limit the imposition
of U.S. estate tax to U.S.-sitused assets. Furthermore, if all U.S.-sitused
assets are owned by a special purpose foreign “blocker” corporation,
then the individual will be deemed to have no taxable U.S. estate. The
concept is simple but the details are complex. We cut through the complexity
by planning and implementing everything with sufficient degree of economic
Castro & Co. has the knowledge and experience that complex global estates require.
Call (888) 595-5088 to learn more and receive the international estate planning assistance
you need from one of our experienced lawyers.