Multi-national Estate Planning
We have been engaged in the representation of multi-national estate
planning clients. The key point is that a U.S. citizen is subject to
estate taxes on his or her worldwide assets. It is only the treaty
between the U.S. and a second country and use of credits that could
mitigate the tax. This involves analysis of the U.S. estate tax system
in connection with the estate tax system of other countries. The U.S.
has entered into treaties with many countries which provide a roadmap
for maximizing estate and tax benefits. (For those clients who have
both Canadian and U.S. citizenship or other multi-national issues,
recent treaty amendments have attempted to reconcile the U.S. estate
tax with the Canadian capital appreciation tax on death by providing
offsetting credits depending upon a number of factors.)
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Aryeh's AIPAC Presentation of June 1, 2008
