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International Trust andEstate Planning THURSDAY - FRIDAY | NOVEMBER 9 - 10, 2017SAN ANTONIO MARRIOTT RIVERWALKSAN ANTONIO, TEXAS

American Law InstituteC O N T I N U I N G L E G A L E D U C A T I O N

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REGISTER BY SEPTEMBER 29 AND

SAVE $200*

OR ADDITIONAL REGISTRANTS

SAVE 50%* S E E B A C K F O RD E TA I L S

T hu r s d ayNovemb er 9 , 2 0 1 7

M O R N I N G S E S S I O NW E B C A S T S E G M E N T A

Foreign Trust-Related Income Tax Issues

• Application of U.S. fiduciary income tax rules to foreign trusts, grantors, trustees, and beneficiaries, including reporting issues

Practical Issues for U.S. Clients with Foreign Trusts

• Interaction of U.S. trust and income tax laws related to foreign trusts and their beneficiaries; realities of trust law and administration outside the U.S.

European Developments

• Developments in offshore financial centers affecting U.S. advisers having clients with foreign property, financial accounts, and trusts

A F T E R N O O N S E S S I O NW E B C A S T S E G M E N T B

FATCA, CRS, and BeneficialOwnership Information Exchange

• Recent developments in automatic tax information exchange and beneficial owner registries; impact on globally mobile high net worth clients

Anti-Money Laundering Rules andOther Ethics Issues

• Due diligence and “know-your-client” principles in U.S. and abroad, including Financial Action Task Force and OECD initiatives related to money laundering

Ethics Roundtable

• Key professional responsibility and ethics concerns for lawyers working with clients with cross-border issues or advising foreign trusts and trustees

Fr i d ayNovemb er 1 0 , 2 0 1 7

M O R N I N G S E S S I O NW E B C A S T S E G M E N T C

Estate Planning for U.S. Clients with Foreign Property

• Considerations for U.S. citizens and residents owning property outside the U.S., including real estate, business interests, and financial accounts

Mexico-Related Issues

• Planning for U.S. clients with Mexican property and for Mexican clients moving to and investing in the U.S.

Immigration and Related Planning

• Immigration planning; visas; investment-based options for permanent resident status; obtaining or terminating U.S. citizenship

Expatriation

• 2008 HEART Act changes; “mark-to-market,” deferred comp, non-grantor trusts; new §2801 “inheritance” tax

A F T E R N O O N S E S S I O NW E B C A S T S E G M E N T D

Income Taxation of Nonresident Aliens

• Determining residency for U.S.income tax purposes; taxableU.S.-source income; tax treaties

Estate and Gift Taxation of Nonresident Aliens

• Application of tax rules to nonresident aliens in the U.S.; planning strategies; effect of income tax treaties

Tax Compliance Initiatives/Voluntary Disclosure

• Latest developments in government initiatives to increase tax compliance

Developments in Offshore Compliance and Enforcement

• Update on IRS initiatives regarding offshore accounts/structures; options for correcting past non-compliance

P R O G R A MM. Read MooreMcDermott Will & Emery LLP

Michael G. PfeiferCaplin & Drysdale, Chartered

Planning Chairs (also on faculty)

Faculty

Mark John BarmesLenz & Staehelin

Sarah M.M. DuckhamTrow & Rahal, P.C.

Michelle B. GrahamWithersworldwide

Ellen K. HarrisonMcDermott Will & Emery LLP

Jonathan JackelEY (Ernst & Young LLP)

Lucy S. LeeAkin Gump Strauss Hauer& Feld LLP

Mark E. MatthewsCaplin & Drysdale, Chartered

Carlyn S. McCaff reyMcDermott Will & Emery LLP

Abel Francisco Mejia-CosenzaSánchez Devanny Eseverri, S.C.

Carolyn A. SchenckSenior Counsel, IRS Offi ce of ChiefCounsel (invited)

John A. Terrill, IIHeckscher, Teillon, Terrill & Sager, P.C.

Brian P. TsuHenderson, Caverly, Pum & Charney LLP

ALI CLE Program Staff :Robert Rushton (rrushton@ali-cle.org)

Come to the premier international trust and estates course with the high-level information and strategies you need to advise both U.S. and international estate planning clients.

Now in its 33rd year, International Trust and Estate Planning never fails to deliver. This year ’s program is no exception, with new sessions that explore current issues in foreign trust-related income tax, concerns involving non-resident aliens, and detailed guidance for staying vigilant when upholding anti-money laundering rules. As always, the course addresses perennial topics such as the complications encountered in estate planning for U.S. clients with foreign property and the complexities of planning for foreign trusts.

SPECIAL FEATURE: Developments in Offshore Compliance and EnforcementAn IRS representative will report on current initiatives aimed at identifying taxpayers using offshore accounts and other tax avoidance and evasion structures, as well as options available for correcting past noncompliance.

“I’m actually sad the program is over. I loved it.” – 2016 attendee

G o t o w w w . a l i - c l e . o r g / C Z 0 1 2t o r e g i s t e r o n l i n e o r f o r m o r e i n f o r m a t i o n a b o u t

t h e p r o g r a m , h o t e l a c c o m m o d a t i o n s ,s t u d y m a t e r i a l s , a n d C L E / C P E c r e d i t .

13.75 C L E C R E D I T H O U R S , I N C L U D I N G2.0 H O U R S O F E T H I C S

16.5 C P E C R E D I T H O U R S I N T A X A T I O N

P R O G R A M

“This is the best panel I have ever experienced in a real estate CLE.”

G o t o w w w . a l i - c l e . o r g / C Z 0 1 2 t o r e g i s t e r o n l i n e o r f o r m o r e i n f o r m a t i o n a b o u t

t h e p r o g r a m , h o t e l a c c o m m o d a t i o n s , s t u d y m a t e r i a l s , a n d C L E / C P E c r e d i t .

November 9, 2017 7:45 AM Registration and

Continental Breakfast

8:50 AM Administrative Remarks – ALI CLE Staff

V I D E O W E B C A S T S E G M E N T A

8:55 AM Opening Remarks and Course Overview

9:00 AM Foreign Trust-Related Income Tax Issues

This presentation will cover the U.S. fiduciary income tax rules that apply to foreign grantor trust and foreign nongrantor trust structures with respect to grantors, trustees, and beneficiaries, including reporting-related issues.

10:40 AM Networking and Refreshment Break

11:00 AM Practical Issues for U.S. Clients with Foreign Trusts

Differences in trust law and trust administration outside of the United States often make advising U.S. clients on U.S. tax issues related to foreign trusts quite challenging. This presentation will address the interaction of U.S. income tax laws related to foreign trusts and their beneficiaries and the realities of trust law and trust administration outside of the United States.

11:50 AM European Developments

This presentation will cover important developments and trends in offshore financial centers that affect U.S. advisers who have clients with foreign property and financial accounts and interests in foreign trusts, including developments in Switzerland.

12:40 PM Lunch for Faculty and Registrants (provided by ALI CLE)

V I D E O W E B C A S T S E G M E N T B

1:45 PM FATCA, CRS, and Beneficial Ownership Information Exchange

This panel presentation will address recent developments in automatic tax information exchange, including FATCA and the Common Reporting Standard, as well as recent developments in beneficial owner registries, all with particular attention to how these developments affect globally mobile high net worth clients, including U.S. citizen and resident clients, and U.S. and non-U.S. trusts and trustees.

3:15 PM Networking and Refreshment Break

3:30 PM Anti-Money Laundering Rules and Other Ethics Issues

This presentation will address due diligence and “know-your-client” principles in the United States and outside the United States that affect lawyers who work with clients on wealth management issues, with particular attention to initiatives of the Financial Action Task Force and the Organization for Economic Cooperation and Development (OECD) with respect to the participation of lawyers in the fight against money laundering and terrorist financing and the U.S. response to those initiatives.

4:30 PM Ethics Roundtable (All faculty)

Faculty members will address important professional responsibility and ethics issues that affect lawyers who work with clients with cross-border issues and foreign trusts and trustees.

5:15 PM Adjournment for the Day

November 10, 2017

7:45 AM Continental Breakfast and Networking Session

V I D E O W E B C A S T S E G M E N T C

8:35 AM Re-Cap of Day One

8:45 AM Estate Planning for U.S. Clients with Foreign Property

Legal and tax issues that arise when U.S. citizen and resident clients own property in foreign countries, including real estate, business interests, and financial accounts.

9:35 AM Mexico-Related Issues

This panel presentation will cover important rules that U.S. estate planning lawyers should know for U.S. clients who invest in Mexican property and for Mexican clients who move to and invest in the United States.

10:25 AM Networking and Refreshment Break

10:40 AM Immigration and Related Planning

Immigration planning for high net worth clients; common non-immigrant (temporary) visas; investment-based options for obtaining permanent resident (green card) status; obtaining and terminating American citizenship.

11:30 AM Expatriation

Expatriation provisions after 2008 HEART Act changes; problems with scope and administration of “mark-to-market,” deferred compensation, and non-grantor trust provisions; new Section 2801 “inheritance” tax; practical issues with advising citizens and long-term residents.

12:30 PM Lunch Break (on your own)

“Overall course was excellent! These are by far the most

informative seminars I have attended. The ALI CLE courses

are the best for attorneys who have been practicing for more than five

years. The topics are advanced enough where you always walk

away having learned something. The faculty is fantastic, as are the

materials.”

R E G I S T E R O N L I N Ew w w . a l i - c l e . o r g / C Z 0 1 2

1 - 8 0 0 - C L E - N E W S [ 2 5 3 - 6 3 9 7 ]

13.75 C L E C R E D I T H O U R S , I N C L U D I N G 2.0 H O U R S O F E T H I C S

16.5 C P E C R E D I T H O U R S I N T A X A T I O N

V I D E O W E B C A S T S E G M E N T D

1:30 PM Income Taxation of Nonresident Aliens

This presentation will address basic U.S. income tax rules that apply to nonresident aliens, including determining when a person is a U.S. resident for U.S. federal income tax purposes, the kinds of U.S.-source income that are subject to tax in the hands of nonresident aliens, and the effect of income tax treaties on residency issues and substantive income tax issues.

2:20 PM Estate and Gift Taxation of Nonresident Aliens

This presentation will cover basic estate, gift, and generation-skipping transfer tax rules that apply to nonresident aliens of the United States who own U.S. situs property, including a discussion of how treaties modify those rules in certain circumstances and estate planning strategies for nonresident aliens with U.S. situs property.

3:10 PM Networking and

Refreshment Break

3:25 PM Compliance Initiatives/Voluntary Disclosure

Latest developments in U.S. government initiatives to encourage and compel compliance with U.S. tax laws with respect to U.S. citizen and resident clients with foreign income and foreign assets.

4:25 PM Developments in Offshore Compliance and Enforcement

Review of IRS initiatives to identify taxpayers using offshore accounts and structures to avoid or evade tax, as well as options available to taxpayers who want to voluntarily correct past noncompliance; new developments

5:15 PM Adjournment for the Day

HOTEL ACCOMMODATIONS

A limited block of rooms has been reserved at the San Anto-nio Marriott Riverwalk. Room rate: $215 per night, single or double occupancy. These rooms will be held as a block, unless exhausted, until October 18, at which time they will be released to the general public. Registrants must make their own hotel reservations and indicate that they attending the ALI CLE Modern Real Estate Transactions conference to qualify for rooms in the block.

Room reservations may be made by calling San Antonio Mar-riott Riverwalk, 889 E Market St, San Antonio, TX 78205; (210) 224-4555 or (800) 648-4462. Confirmations will be sent by the hotel. Please read the cancellation policy carefully.

STUDY MATERIALS

Going green in 2017! Course materials will be available in electronic format for download the week before and during the course. Print materials will not be distributed. All registrants are advised to bring laptops or tablets to the course to view the course materials, including updates.

Go to www.ali-cle.org/CZ012 for more info about: Registration/cancellation/requirements for persons with disabilities/scholarships

MANDATORY CLE CREDIT

ALI CLE programs are accredited in all MCLE jurisdictions. Credit in CO is available by reciprocity; credit in ID, LA, and RI is available upon request. For specific information on CLE, CPE, or other professional accreditation in your state, e-mail TeamMCLE@ali-cle.org, go to http://www.ali-cle.org/mcle, or call 1-800-CLE-NEWS.

NASBA

ALI CLE is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continu-ing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. For information on ALI CLE’s complaint

and refund policies, call Customer Service at (800) CLE-NEWS. CPE Credit hours for this course: 16.5 in Taxation. Learning Objectives: Acquisition of knowledge and

skills to develop proficiency as a practitioner; maintenance of professional competence as a practitioner. Suggested Prerequisite: Experience in practice in subject matter. Level of Instruction: Advanced

ADDITIONAL INFORMATION

Employee Benefit Plans Of Tax-Exempt And Governmental Employers

ALSO FROM ALI CLE

Featuring Practical Solutions to Problems under the Internal Revenue Code, ERISA, Other Federal Laws, and State Law Requirements

THURSDAY - FRIDAYOCTOBER 5 - 6, 2017WASHINGTON PLAZA HOTELWASHINGTON, DC

Register by AUGUST 31, 2017 and

SAVE $200.*

Enter coupon code CZ009EB2 at checkout.

www.ali-cle.org/CZ009

30TH ANNUAL ADVANCED COURSE and LIVE VIDEO WEBCAST