
International Private Client Services
In an era marked by dynamic global changes, Wiggin and Dana’s experience extends beyond conventional boundaries, offering strategic guidance to cross-border clients. U.S. citizens, foreign nationals and international families alike rely on Wiggin and Dana’s counsel to help them find innovative and cost-effective solutions to their complex multi-jurisdictional investment, cross-border taxation, international estate planning and asset-protection issues and litigation needs.
Our attorneys provide knowledgeable planning services to U.S. citizens who live, work or hold assets abroad, working to smooth administrative issues and minimize tax burdens. For foreign nationals, we provide pre-immigration planning advice, including with regard to tax-efficient structures to hold U.S. property investments. We routinely prepare Qualified Domestic Trusts (QDOTs) for non-U.S. citizen spouses, Excluded Property Trusts for U.S. taxpayers establishing residence in the U.K., pre-immigration trusts for foreign nationals moving to the U.S., and dynasty trusts excluded from U.S. estate and generation-skipping transfer tax for U.S. resident family members of foreign nationals. We also prepare federal estate tax returns for foreign nationals who die owning U.S. assets and assist their families in obtaining federal transfer tax certificates for the release of U.S. bank and investment accounts owned by non-U.S. decedents. Multi-jurisdictional families with U.S. investments appreciate our expertise in complex cross-border asset ownership structuring and tax planning, as well as our thoughtful advice on asset protection, expatriation and the administration of onshore and offshore trusts.
Personalized Strategies for Global Citizens with Complex Legal Needs
At Wiggin and Dana, we understand that global citizens have complex legal needs that require tailored expertise. From helping clients manage foreign grantor trusts or income accumulated in a passive foreign investment company, to cross-border litigation and multi-jurisdictional disputes, our International Private Clients Services attorneys provide customized legal solutions to individuals, families, and international family offices worldwide.
Our team has a deep understanding of the cultural, legal, and financial complexities that come with cross-border wealth planning, including estate planning, tax planning, and wealth preservation. We work closely with our clients to develop personalized strategies that maximize financial benefits while minimizing legal risks.
Announcing the Launch of Our “International Estate Planning Series”
To provide additional education and support to U.S. citizens and foreign nationals with multi-jurisdictional investment, tax, and estate planning needs, Wiggin and Dana is proud to announce the launch of our new International Estate Planning Series, a publication designed to help international families and individuals navigate the complex legal landscape of cross-border wealth management.
Our series will cover a wide range of topics, from living, working, and investing across borders to tax planning strategies and risk management techniques for trusts. As global citizens face increasing legal challenges in their personal and professional lives, this series aims to provide actionable insights and practical advice for managing legal risks and maximizing financial benefits in the international arena.
We will address diverse topics and issues, including U.S. estate tax treaties, the U.S. expatriation tax, and the proper filing of FBAR and FATCA reports. We look forward to sharing our expertise with you through this series and helping you achieve your personal and professional goals.
International Private Client Services: Our Proven Track Record
At Wiggin and Dana, our success in providing international private client services to high-net-worth individuals, families, and international family offices worldwide is unmatched. We have successfully handled the most complex international legal matters, ranging from cross-border estate planning to tax compliance and international litigation. Our team’s holistic understanding of international legal and financial frameworks has enabled us to provide tailored solutions to our clients, mitigating legal risks while maximizing financial benefits. We have listed a few examples of our recent experience below:
- Represented the fiduciary of an estate involving competing Spanish and U.S. wills and extensive litigation in both Spain and the U.S. that also involved litigation to preserve business assets and commercial landlord/tenant disputes arising from the breach of settlement agreements.
- Advised a mediator in connection with efforts to resolve multiple lawsuits arising in the context of disputed estate and trust accounting proceedings where property was held in the U.S., Canada and Israel.
- Representing the co-fiduciary of an estate matter involving disputes over the ownership of foreign bank accounts, competing Israeli wills and their ultimate impact on the disposition of valuable real estate, the defense of a related U.S. Internal Revenue Service estate tax audit and related appeal to the U.S. Tax Court, allegations against the other co-fiduciary for fraud and misappropriation of assets and issues concerning the ownership of a foreign corporation.
- Advising the widow of a wealthy non-U.S. citizen regarding the improper conversion of a single-member LLC that owned valuable real estate located in Europe and related discovery in multiple countries.
- Represented the elderly widow, and fiduciary of the estate of a successful New York-based businessman with respect to competing wills in Israel and New York.
- Represented a dual French–U.S. national in connection with a family dispute involving assets located in the U.S. and France.
- Advised a Mexican based family in connection with the transfer of the family’s offshore trust structure, consisting of a UK trust and Scottish companies to the United States and Mexico.
- Advised the executors of a Canadian estate on U.S. estate and income tax matters related to the decedent’s private Canadian corporation, involving passive foreign investment company (PFIC) and controlled foreign corporation (CFC) issues.
- Obtained a $582 million judgment in favor of a Kuwaiti national in a Connecticut State Court proceeding arising from fraudulent misrepresentations concerning paternity and the related extortion of hundreds of millions of dollars. The damages phase of this case involved the taking of discovery in Switzerland under the Hague Convention.
- Advised a family with ties to China, Singapore and Hong Kong on the creation of pre-immigration trusts in Bermuda and Delaware.
When it comes to estate and gift taxation, non-U.S. citizens face unique challenges based on their residence and domicile status. Understanding these concepts is crucial for effective estate planning and… Estate planning can require extra care and effort where one spouse is not a U.S. citizen. The same can be said for couples who live, work, or own property in… Overview Individuals who are neither United States citizens nor U.S. “domiciled” (U.S. resident with an intention to remain indefinitely in the U.S.) are subject to a less favorable estate tax… As the new year approaches, we present our annual year-end advisory for 2023. This edition highlights noteworthy estate and gift tax changes in the law and outlines planning opportunities that… The family beach house, ski condo, lake cottage, or other vacation property is often cherished for the lifelong memories created and the traditions upheld. Understandably, many people want to keep… The Private Client Services team is pleased to share Part II of the “Estate Planning with Digital Assets” series. In the first part of this two-part series (click here to… The Private Client Services team is pleased to announce the launch of the “Estate Planning with Digital Assets” series. In the first issue, Vanessa L. Maczko and Beth A. Scharpf… The Private Client Services team is pleased to announce the launch of the “International Estate Planning” series. In the first issue, authors Carolyn Reers and Mi-Hae Russo discuss the interconnectivity… As we approach the latter half of 2022, our Private Client Service team would like to share some exciting updates in the areas of: Estate Planning Business Succession Planning Fiduciary… Wiggin and Dana’s Immigration and Nationality Law and Compliance Practice Group addresses the spectrum of business immigration needs for employers and related individuals, including the incidental compliance areas that intersect… Who should I nominate as the Executor of my Will? Who should be the Trustee of my Trust? Should the Executor and Trustee be the same person? Should I nominate… Often the most difficult decision parents need to make when writing a Will is whom to appoint as the trustee for their children. The choice becomes particularly tricky for clients… As the year draws to a close, we have entered a period of great uncertainty in estate and tax planning. President-elect Donald Trump has identified tax reform as a priority… Proposed tax regulations issued on August 2, 2016 could eliminate or radically reduce the availability of valuation discounts in connection with the transfer of interests in closely held entities to…Publications
Podcasts
On the fifth episode of our speaker series, Partner Carolyn Reers explores the growing trend of high-net-worth individuals seeking residency or citizenship abroad for tax benefits and safety. She highlights…
Jacob Koenig, Managing Director and Partner of Woodbridge International, sits down with Partners Erin Nicholls and Michael Clear to discuss his firm’s unique approach to selling companies, including their focus…
In the latest podcast episode, host Michael Clear introduces the “Future Focused: Private Wealth Insights” blog, a platform designed to help optimize and protect your financial future. Explore domestic and…
On this episode, Partner Michael Clear sits down with Larry Lipoff, CPA, TEP, CEBS, who is a Director in CohnReznick’s Trusts and Estates Practice, to discuss the key takeaways from…
There has been a longstanding effort globally and a lot of pressure on the United States to implement some sort of registry on a federal level for ownership of small…
Trustees behaving badly? In this episode of “Future Focused,” Partners Erin Nicholls and Michael Clear discuss trusts and mechanisms available for a trust beneficiary to remove a trustee. From understanding…
On this episode, join Partners Dan Daniels and Michael Clear as they discuss the importance of educating the next generation on estate planning matters. From the protection of assets in…
On this episode, join Partners Erin Nicholls and Michael Clear as they discuss mechanisms we have at our disposal to “fix” an irrevocable trust. The use of decanting, which is…
On this episode, join Partners Erin Nicholls and Michael Clear as they discuss key considerations when addressing Generation-Skipping Transfer (GST) Tax. With a particular focus on interesting planning opportunities and…
On this episode, join Partners Michael Clear and Vanessa Maczko as they discuss estate planning considerations for digital assets, which often require special attention when compared to more traditional assets,…
On this episode, join Partners Erin Nicholls and Michael Clear as they discuss strategies for preserving family legacy assets across generations. With a particular focus on the management and division…
On this episode, join Partners Erin Nicholls and Michael Clear as they delve deeper into a discussion on creating SLATs for married clients to use up both clients’ lifetime exemption…
On this episode, join Partners Erin Nicholls and Michael Clear as they discuss one of the hottest topics in the estate planning world, spousal lifetime access trusts (SLATs), and the…
On this episode, join Partners Erin Nicholls and Michael Clear as they dispel some of the common misconceptions related to trust planning and delve into the three reasons why trust…