Tax Planning for US Equities Owned in a Non-US Trust Structure

Advisers to international families will often hear US tax professionals using the terms ‘basis step up’ and ‘estate tax blocker’. While a family may never have any US citizen or resident members, keeping in mind US tax basis and estate tax issues while establishing and maintaining a succession planning structure can protect the estate of a non-US settlor from US estate tax and prove beneficial after the settlor’s death in the event that a branch of the family moves to the United States or a family member marries a US citizen. Recent changes to the US Tax Code have prompted some US tax advisers to suggest additional layers of entities to the structure, the additional cost and complexity of which may not result in substantial tax savings. Download