International Trust &
Estate Planning

RGF has a particular niche expertise with respect to international structures, including trusts, entities, investments, and life insurance policies that are sitused offshore, as well as associated foreign tax planning, reporting, and compliance matters.

The implementation of thoughtful and well-designed foreign holdings is instrumental not only in helping our clients achieve their aims of wealth preservation and wealth transfer, but also in mitigating risk to provide our clients with peace of mind.

In the area of “outbound” international estate planning and asset protection planning, our professionals are experienced in assisting U.S. clients with settling international trusts and forming various foreign entities that provide clients with protection of assets, allowing clients to manage their family’s wealth risk and accumulate assets for future generations.  We have particular expertise in advising with respect to FATCA (the “Foreign Account Tax Compliance Act”), CRS (the “Common Reporting Standard” promulgated by the OECD), and the CTA (the “Corporate Transparency Act”) and we frequently advise U.S. and non-U.S. clients, including foreign trust and protector companies, regarding their due diligence and disclosure obligations.

With respect to “inbound” international estate planning, we assist U.S. taxpayers and non-U.S. trustees with managing the complex U.S. tax aspects of foreign non-grantor trusts. In addition, we advise on multi-jurisdictional tax and treaty issues faced by international private clients, whether in connection with family members or business interests in and outside of the U.S., pre-inheritance planning, pre-immigration planning, or with the tax treatment of trusts or entities they have created or plan to create.  We frequently advise foreign investors with respect to optimization of U.S. real estate investments, including the establishment of U.S. real property holding structures, guidance regarding FIRPTA (the “Foreign Investment in Real Property Tax Act”), and estate, gift, and income tax planning with respect to such properties.