Multinational Estate Planning Representative Matters

A sampling of matters we have handled includes our representation of:

  • A Japanese conglomerate in its estate planning business in Japan and its estate administration business in the United States with a major trust company.
  • Off-shore corporate trustees in the restructure of a U.S. beneficiary trust and the liquidation of a controlled foreign corporation (CFC), the total income of which was attributed to the U.S. income beneficiary, even though the beneficiary was receiving minimal distributions.
  • U.S. trustees and Jersey (Channel Islands) trustees in connection with change of situs of four off-shore trusts.
  • The owner of a closely held Japanese corporation, worth more than $100 million, doing business in the United States in connection with an estate plan.
  • A U.S. beneficiary of a large South African estate on the tax consequences of distribution of the estate.
  • High net worth non-U.S. residents regarding gifting opportunities to U.S. beneficiaries.
  • A U.S. winery owner with properties in France in connection with estate planning.
  • A U.S. trust beneficiary residing in Japan in tax planning that saved approximately $30 million in Japanese inheritance taxes for the client.
  • Families in Japan through administration proceedings in the New York Surrogate Court to settle estates holding New York assets, including New York ancillary probates.
  • The son of a founder of a listed Japanese retail company in connection with estate planning and the purchase of $250 million in life insurance.
  • Fiduciaries of estates of Japanese decedents with assets in New York in the filing of nonresident estate tax returns.
  • A U.S. guardian of a Japanese ward in successfully settling accounts located in Japanese financial institutions.
  • The estate of the developer of a submachine gun who was a dual U.S.-Israeli citizen at the time of his death. We handled the transfer of assets to a non-U.S. citizen beneficiary and worked with the Bureau of Alcohol, Tobacco and Firearms with respect to the inventory of a substantial firearms collection, firearms parts and obtaining authorization for the legal international transport of several experimental and "collector" firearms.
  • A U.S. citizen in a relationship with (but not married to) an Israeli citizen in developing an agreement to ensure that after his death, the woman would not be able to claim that a common law marriage existed between them under Israeli law.