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Articles, presentations, rankings, and news — from foreign trusts and beneficial ownership reporting to cross-border income and estate planning. Filter by type, topic, author, or year.

69 results

June 2026

International Real Estate Planning: Structuring Investments in U.S. Real Estate

Belgium

Severiano Ortiz has the pleasure of presenting on “International Real Estate Planning: Structuring Investments in U.S. Real Estate” and related planning considerations as part of an International Private Client Club Event, established by the legal team of ZADAL Abogados y…

Presentation U.S. Real Estate and FIRPTA Severiano E. Ortiz

April 2026

AICPA ENGAGE 2026 CONFERENCE

Las Vegas

Severiano Ortiz presents at the AICPA ENGAGE 2026 Conference. His session, What The CPA Needs To Know About Foreign Trusts, focuses on the application of the U.S. tax laws as they relate to identifying a client’s foreign versus domestic trust…

Presentation Foreign Trusts Severiano E. Ortiz

September 2025

U.S. Tax Compliance for U.S. Income Tax Residents Abroad

Webinar

Severiano Ortiz presents as part of a webinar series entitled, The Motherland Expert Session: Divesting financially from the US. Webinar. September 8, 2025.…

Presentation Compliance and DisclosureCross-border Income TaxExpatriation and Outbound Investment Severiano E. Ortiz

April 2025

Trusts – Legal/tax implications and reporting obligations around the world

France, Paris

Severiano Ortiz has the pleasure of presenting on “U.S. and Foreign Trusts” and related planning considerations as part of an International Private Client Club Event, established by the legal team of ZADAL Abogados y Asesores Tributarios in Madrid, Spain and…

Presentation Compliance and DisclosureForeign Trusts Severiano E. Ortiz

September 2024

When U.S. Tax Residents Invest and Own Assets Abroad

South Africa

Severiano Ortiz, Eric Huang, and John Kim have the pleasure of presenting on “When U.S. Tax Residents Invest and Own Assets Abroad” and related planning and drafting considerations before the team at Investec Wealth & Investment International (Link) in South…

Presentation Expatriation and Outbound Investment Severiano E. OrtizEric Huang

September 2024

STEP Mid-Atlantic Panel Discussion: Proposed Foreign Trust Regulations

Washington D.C.

Eric Huang co-presents a panel entitled Proposed Foreign Trust Regulations. This panel examines the recently proposed Treasury Regulations regarding foreign trusts and large foreign gifts, including loans from foreign trusts, use of foreign trust property, Form 3520/3520A reporting, and penalties. This…

Presentation Compliance and DisclosureCross-border Estate & GiftForeign Trusts Eric Huang

September 2024

South African Trusts with U.S. Connections: U.S. Tax Considerations

South Africa

Severiano Ortiz, Eric Huang, and John Kim have the pleasure of presenting on “South African Trusts with U.S. Connections” and related planning and drafting considerations before the team at Investec Wealth & Investment International (Link) in South Africa. September 4,…

Presentation Foreign Trusts Severiano E. OrtizEric Huang

April 2024

Building a Sustainable Future: Exploring the intersection of tax and real estate.

Frankfurt, Germany

Severiano Ortiz participates in the AIJA Taxation and Real Estate Conference with attorneys from around the world. The event’s theme is “Building a Sustainable Future: Exploring the intersection of tax and real estate.” Frankfurt, Germany. April 25-27, 2024.…

Presentation Cross-border Estate & GiftU.S. Real Estate and FIRPTA Severiano E. Ortiz

April 2024

U.S. Persons Moving and Investing Abroad

Italy, Milan

Severiano Ortiz has the pleasure of presenting on “U.S. Persons Moving and Investing Abroad” and related planning considerations as part of an International Private Client Cub Event, established by the legal team of ZADAL Abogados y Asesores Tributarios in Madrid,…

Presentation Expatriation and Outbound Investment Severiano E. Ortiz

March 2024

Foreign Trusts: From a U.S. Perspective

Madrid, Spain

Severiano Ortiz has the pleasure of presenting on “Foreign Trusts: From a U.S. Perspective” and related planning considerations before the legal team of ZADAL Abogados y Asesores Tributarios (Link) in Madrid, Spain. March 22, 2024.…

Presentation Foreign Trusts Severiano E. Ortiz

October 2023

Corporate Transparency Act – Dealing with the new world of beneficial ownership and control disclosure

New York City

Severiano Ortiz co-presents at NYU’s 82nd Institute on Federal Taxation. His session, Corporate Transparency Act – Dealing with the new world of beneficial ownership and control disclosure, focuses on the enactment of the Corporate Transparency Act that goes into effect…

Presentation Beneficial Ownership/Corporate TransparencyCompliance and Disclosure Severiano E. Ortiz

August 2023

Life in Another World: Inbound Foreigners and Outbound Americans – Chicago, Illinois 2023

Chicago, Illinois

Severiano Ortiz presents at LOMA/LIMRA’s 2023 Advanced Sales Forum: Inspired to Make a Positive Difference conference. His session, Life in Another World: Inbound Foreigners and Outbound Americans, focuses on the tax and immigration planning considerations of cross-border individuals and families…

Presentation Expatriation and Outbound InvestmentPre-immigration and Inbound Investment Severiano E. Ortiz

June 2023

U.S. Taxation: Cross-Border Income and Estate Tax Planning – Madrid, Spain 2023

Madrid, Spain

Severiano Ortiz presents U.S. Taxation: Cross-Border Income and Estate Tax Planning at a gathering of international tax and private client attorneys hosted by Zadal Abogados Y Asesores Tributarios. Private Client International Meeting, Madrid, Spain. June 8-9, 2023.…

Presentation Cross-border Estate & GiftCross-border Income Tax Severiano E. Ortiz

March 2023

Fund and Fee Structures – a myriad of cash flows, waterfalls and taxes – Bergen, Norway

Bergen, Norway

Severiano Ortiz moderates a panel with Charles S. Duro (Duro Partners, Luxembourg), Céline Martin (Riedweg & Partner, Switzerland), and Clément Riccio (Sumerson, France) on Fund and fee structures – a myriad of cash flows, waterfalls and taxes. This panel focuses…

Presentation Cross-border Income TaxExpatriation and Outbound Investment Severiano E. Ortiz

October 2022

An Update on U.S. Transparency Initiatives

Society of Trust & Estate Practitioners, Webinar

Severiano Ortiz co-presents on An Update on U.S. Transparency Initiatives. The Webinar covers three topics: (1) the final beneficial ownership information (BOI) reporting regulations under the Corporate Transparency Act; (2) the Enabler’s Act, and (3) US sanction developments in the…

Presentation Beneficial Ownership/Corporate TransparencyCross-border Estate & GiftForeign Trusts Severiano E. Ortiz

October 2022

Estate Planning for Multinational Families

Chicago Bar Association, Webinar

Eric Huang co-presents a live webinar on the Transfer and Income Tax Considerations for Estate Planning for Multinational Families to the Chicago Bar Association Trust Law Committee on October 17, 2022. This presentation includes an overview of determining US residency…

Presentation Cross-border Estate & GiftCross-border Income TaxForeign TrustsPre-immigration and Inbound Investment Eric Huang

September 2022

Portugal and Spain – From Golden Visas to Tax Considerations for High-Net-Worth Individuals in Search of the Sun

Society of Trust & Estate Practitioners, Webinar

Severiano Ortiz co-presents with Tiago Cassiano Neves (Kore Partners in Lisbon, Portugal) and Pedro Jesus Fernandez (Kinship Law Partners in Madrid/Marbella, Spain), Portugal and Spain – From Golden Visas to Tax Considerations for High-Net-Worth Individuals in Search of the Sun.…

Presentation Cross-border Estate & GiftForeign TrustsPre-immigration and Inbound Investment Severiano E. Ortiz

September 2022

Portuguese Residency By Investment

Lisbon, Portugal, Webinar

Severiano Ortiz joins Luiz Felipe Maia, Founder at Maia International Properties; Vanessa Rodrigues Lima, Founder of VRL Legal; and Michael Maxwell, Head of Business Development at EQTY Capital to present on residency by investment programs in Portugal. With recent market…

Presentation Pre-immigration and Inbound Investment Severiano E. Ortiz

April 2022

Golden Visa Fund Route for U.S. Investors and PFIC Demystification

Lisbon, Portugal, Webinar

Severiano Ortiz participates as part of a panel entitled Golden Visa Fund Route for U.S. Investors and PFIC Demystification, via a live Webinar on April 28, 2022. The panel is hosted by Optylon Krea in Lisbon, Portugal, and produced through…

Presentation Pre-immigration and Inbound Investment Severiano E. Ortiz

April 2022

U.S. Investment in Portuguese Private Equity

Lisbon, Portugal, Webinar

Severiano Ortiz presents, U.S. Investment in Portuguese Private Equity, for a Live Webinar on April 19, 2022, hosted by Lince Capital in Lisbon, Portugal. The presentation introduces U.S. investors to the myriad of tax filings and elections that apply to…

Presentation Expatriation and Outbound Investment Severiano E. Ortiz

April 2022

Portugal’s Golden Visa Program and U.S. Taxation

Lisbon, Portugal, Webinar

Severiano Ortiz and Eric Huang present, Portugal’s Golden Visa Program and U.S. Taxation, for a Live Webinar on April 5, 2022. This presentation proves an overview of U.S. income, estate, and gift tax considerations that are applicable U.S. persons who…

Presentation Cross-border Estate & GiftPre-immigration and Inbound Investment Severiano E. OrtizEric Huang

March 2022

Foreign Trusts from a U.S. Perspective

Guernsey, Society of Trust & Estate Practitioners, Webinar

Severiano Ortiz presents Lunchtime Lecture No. 14, Foreign Trusts from a U.S. Perspective, as part of the Guernsey Lecture Series 2021/2011, sponsored by STEP Guernsey. This lecture focuses on the application of the U.S. tax laws as they relate to…

Presentation Cross-border Income TaxForeign TrustsPre-immigration and Inbound Investment Severiano E. Ortiz

March 2022

Portuguese Private Equity Funds: U.S. Tax Compliance for U.S. Investors

Lisbon, Portugal, Webinar

Severiano Ortiz and Eric Huang present, Portuguese Private Equity Funds: U.S. Tax Compliance for U.S. Investors, for a Live Webinar on March 17, 2022, hosted by Iberis Capital in Lisbon, Portugal. This presentation covers some of the required U.S. tax…

Presentation Compliance and Disclosure Eric HuangSeveriano E. Ortiz

March 2022

Tax Transparency: Oligarchs & Sanctions | Freezes | Seizures

ABA Section of Taxation, IBA Taxes Committee, IFA–USA Branch, Webinar

Severiano Ortiz co-presents at the Virtual 22nd Annual U.S. and Europe Tax Practice Trends Conference, cosponsored by the ABA Section of Taxation, IBA Taxes Committee, and IFA–USA Branch. March 28 – April 1, 2022. Tax Transparency – Oligarchs & Sanctions…

Presentation Beneficial Ownership/Corporate TransparencyCompliance and Disclosure Severiano E. Ortiz

January 2022

Proposed Regulations – Corporate Transparency Act

Society of Trust & Estate Practitioners, Webinar

Severiano Ortiz co-presents on the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed regulations on Dec. 7, 2021, seeking to implement the “beneficial ownership information” (BOI) requirement of the Corporate Transparency Act (CTA), which was passed…

Presentation Beneficial Ownership/Corporate TransparencyCross-border Estate & GiftForeign Trusts Severiano E. Ortiz

March 2021

Tax Transparency and Beneficial Ownership Developments Affecting Private Clients

American Bar Association, Tax Section, Webinar

Severiano Ortiz presents on Tax Transparency and Beneficial Ownership Developments Affecting Private Clients. This presentation is a part of the Wealth Planning Workshop. This presentation provides an overview of tax transparency and beneficial ownership developments in the U.S., the U.K.,…

Presentation Beneficial Ownership/Corporate Transparency Severiano E. Ortiz

March 2021

International Tax Developments (Inbound)

45th Annual Tax Law Conference, Federal Bar Association…

Presentation Cross-border Income TaxPre-immigration and Inbound Investment Summer A. LePree

January 2021

The Future of Trusts – Threats, Challenges, and Solutions

Cayman Islands, Society of Trust & Estate Practitioners

Our panel discusses recent global developments flowing from the international push towards regulation and transparency, important decisions of the courts that have contributed to the evolution of trust laws around the world, and debate what new challenges may lie ahead.…

Presentation Beneficial Ownership/Corporate TransparencyCross-border Estate & GiftForeign Trusts Severiano E. Ortiz

December 2020

Special Residency & Citizenship Programs: Austria | Bahamas | Ireland | Italy | Portugal | Spain | UK

Society of Trust & Estate Practitioners, Webinar

In recent months, there has been a trend of US citizens as well as non-EU citizens seeking legal advice in relation to selected countries special residency or citizenship programs. Our Webinar provides high level information and pre-immigration planning about these…

Presentation Cross-border Estate & GiftForeign TrustsPre-immigration and Inbound Investment Severiano E. Ortiz

September 2020

UK-US Tax Planning: Trusts, Residential Real Estate, and Real Estate Investment Planning

Society of Trust & Estate Practitioners, Webinar

Discusses the complexities of UK-US tax planning while considering the application of income, gift, and estate tax regimes on various structures. Topics include: Advising trustees of offshore trusts – with a beneficiary in US v beneficiary in UK, including UK…

Presentation Compliance and DisclosureCross-border Estate & GiftForeign TrustsU.S. Real Estate and FIRPTA Severiano E. Ortiz

December 2019

Identifying Business and Investment Trusts

Present lecture on how to identify whether a trust is in fact a trust for U.S. tax purposes. Often times we are working with “trusts” that are actually Investment or Business Trusts and more properly treated as disregarded entities, corporations,…

Presentation Foreign Trusts Severiano E. Ortiz

December 2019

Cross-Border Individual Matters

GW Law’s 32nd Annual Institute on Current Issues in International Taxation…

Presentation Cross-border Income Tax Summer A. LePree

October 2019

U.S. Tax Implications of Offshore Trusts

Present lecture on assessing trust structures from a U.S. income tax perspective. RSM US LLP – Internal Private Client Training. October 1, 2019.…

Presentation Compliance and DisclosureCross-border Income TaxForeign Trusts Severiano E. Ortiz

May 2019

Cross-Border Estate Planning

This panel focuses on provisions of the US tax code relevant to assessing and implementing cross-border estate planning. Points of discussion include identifying the tax status of the taxpayer and the taxpayer’s family (i.e. citizenship, tax residency, domicile), the type…

Presentation Cross-border Estate & GiftCross-border Income TaxPre-immigration and Inbound Investment Severiano E. Ortiz

May 2019

Analyzing Foreign Trusts

This panel focuses on the application of the US tax laws as they relate to identifying foreign versus domestic trust structures. This panel outlines a roadmap from which to analyze trust deeds and discussed some of the key nuances in…

Presentation Cross-border Income TaxForeign TrustsPre-immigration and Inbound Investment Severiano E. Ortiz

January 2019

Section 962 in Cross-Border Tax Planning

37th Annual Florida Bar/FICPA International Tax Conference…

Presentation Cross-border Income TaxExpatriation and Outbound Investment Summer A. LePree

December 2018

Cross-Border Individual Matters

GW Law’s 31st Annual Institute on Current Issues in International Taxation…

Presentation Cross-border Income Tax Summer A. LePree

November 2018

Cross-Border Tax Issues Affecting the Private Client Services Client

Our presentation covers the basics of cross-border estate/gift/income tax planning with a focus on identifying tax residency and domicile, domestic versus foreign trusts, international information compliance, and delinquent filing procedures. RSM US LLP – National Internal Training. November 28, 2018.…

Presentation Compliance and DisclosureCross-border Estate & GiftCross-border Income TaxForeign TrustsPre-immigration and Inbound Investment Severiano E. Ortiz

September 2018

Review of International Informational Reporting Forms and Related IRS Compliance

Conduct an internal training for our private client department to teach its tax professionals about the application of the U.S. Income Tax Code and related international informational filings. RSM US LLP – Internal Private Client Training. September, 28, 2018.…

Presentation Compliance and DisclosureCross-border Income Tax Severiano E. Ortiz

August 2018

Application of the U.S. Gift and Estate Tax Code to Cross-border Families

Conduct an internal training for our private client department to teach its tax professionals about the application of the U.S. Estate and Gift Tax Code to non-resident aliens and cross-border families. RSM US LLP – Internal Private Client Training. August…

Presentation Cross-border Estate & Gift Severiano E. Ortiz

February 2017

Pre-Immigration Planning

International Fiscal Association – U.S. and Switzerland Branches…

Presentation Pre-immigration and Inbound Investment Summer A. LePree

January 2017

Section 956 Final Regulations

This presentation discusses the Final Section 956 Regulations, including, the changes from the September Proposed Regulations and the application of the rules to partnerships. PwC US – International Tax Services Practice Technical Update Meeting. January 17, 2017.…

Presentation Cross-border Income Tax Severiano E. Ortiz

August 2016

CFC Decontrol in Light of Proposed Regulation 385

This presentation discusses the basics of a controlled foreign corporation and the complications of de-controlling it with respect to Proposed Regulation 385, local country constraints, and the impact of section 367(b) and 904(f). PwC US International Tax Services Business Development…

Presentation Cross-border Income TaxExpatriation and Outbound Investment Severiano E. Ortiz

March 2016

Final Regulations on Form 8938, Reporting for Specified Foreign Financial Assets, Regarding Specified Domestic Entities

Final Regulation (T.D. 9752), was published and became effective February 23, 2016. This final regulation adopts the 2011 Proposed Regulation § 1.6038D-6, with certain modifications. It establishes when a domestic corporation, domestic partnership, or trust is considered to be a…

Presentation Compliance and DisclosureCross-border Estate & GiftForeign TrustsU.S. Real Estate and FIRPTA Severiano E. Ortiz

September 2015

US Activities of Foreigners & Tax Treaties – Residence: Beyond the Basics

This program examines the concept of “residence” for alien individuals, including the variety of statutory and regulatory rules that apply for income tax, estate and gift tax and other purposes, the many definitions and uses of the term, and the…

Presentation Cross-border Estate & GiftCross-border Income TaxPre-immigration and Inbound Investment Severiano E. Ortiz

July 2015

The Basics of U.S. Tax Planning for Non-U.S. Persons/Non-Resident Aliens

This panel addresses the basics of what is known in the international tax planning community as inbound tax planning: When does a non-U.S. person become subject to U.S. taxation? What exactly is U.S. source income, effectively connected income (“ECI”), or…

Presentation Cross-border Income TaxPre-immigration and Inbound Investment Severiano E. Ortiz

May 2015

HUF HUF and Blow the IRS Away: An Analysis of a Hindu Undivided Family (HUF) – Is it an Entity or a Trust? Neither? A Tenancy in Common? How does it Comply with U.S. Tax Laws?

Absent any IRS guidance on a HUF, how should practitioners counsel their clients in light of the increased information sharing due to FATCA and inter-governmental agreements? This panel explores the cross-section of U.S. tax classifications, income and transfer tax implications,…

Presentation Compliance and DisclosureCross-border Estate & GiftCross-border Income TaxForeign Trusts Severiano E. Ortiz

May 2015

Hot Topics in International Tax: Foreign Tax Compliance

This panel addresses several recent developments in international tax, with a focus on issues that young lawyers and new practitioners are likely to encounter in practice. The panelists discuss a variety of topics, including BEPS action plans and their impact…

Presentation Compliance and DisclosureCross-border Income TaxExpatriation and Outbound Investment Severiano E. Ortiz

May 2015

Pre-Immigration Planning: Rescuing the Client Who Failed to Plan or File the Required Forms

Learn about the common pitfalls practitioners face in completing the required forms, when a mistake requires more than simply ling a delinquent form, how to choose the right type of disclosure program for a client, and the strategies and risks…

Presentation Compliance and DisclosureCross-border Estate & GiftForeign TrustsPre-immigration and Inbound InvestmentU.S. Real Estate and FIRPTA Severiano E. Ortiz

March 2015

Final Regulations on Form 8938, Reporting of Specified Foreign Financial Assets

Final regulation (T.D. 9706), was published and became effective December 12, 2014. This final regulation adopts the 2011 temporary regulations as final regulations, with certain modifications. It did not yet, however, adopt Proposed Regulation § 1.6038D-6 (which would require entities…

Presentation Compliance and DisclosureCross-border Estate & GiftForeign TrustsU.S. Real Estate and FIRPTA Severiano E. Ortiz

January 2015

Civil and Criminal Tax Penalties – Legislative and Administrative Developments

This presentation provides a summary of updated legislative and administrative developments with regard to IRS penalties and IRS international disclosure procedures. American Bar Association Section of Taxation – 2015 Midyear Meeting. January 31, 2015.…

Presentation Compliance and Disclosure Severiano E. Ortiz