International Estate Planning
for the Domestic Estate
Planner
The members of the Estate Planning and Probate Section thank the contributors for
sharing their time and knowledge.
CHRIS BENNER
Bennett Thrasher, LLP
[email protected]
On January 8, 2020, the Estate Planning &
Probate Section of The Atlanta Bar gathered
to hear a partner in the Personal Financial
Services, Chris Benner (Bennett Thrasher,
LLP), discuss income and transfer tax issues
in international estate planning.
The United States taxes income based on
18
February/March 2020
MARTINA ECHEVERRIA
The Saylor Law Firm, LLP MURRAY SAYLOR
The Saylor Law Firm, LLP
residency. It is generally preferable to be a
nonresident for income tax purposes. A U.S.
resident is taxed on worldwide income, while
a nonresident alien ("NRA") is only taxed on
U.S. sourced income. NRAs not only avoid
U.S. taxation of foreign-source income, but in
many cases, they also enjoy reduced income
tax rates or exclusions under a tax treaty. Additionally, nonresident aliens are not
subject to net investment income tax.
mecheverria@saylorlaw.
com
[email protected]
Benner explained that international tax issues
are relevant to domestic estate planning.
Seemingly, domestic-only matters often
involve unexpected international estate
planning issues. Additionally, with foreign