Chinese Clients, Global Citizens – From Foreign Non-Grantor Trusts to Asset Protection and Multijurisdictional Challenges
US tax and trust planning for Chinese clients is generally the same as that for other international clients. However, given certain unique challenges they face, some special considerations and important variations are warranted.
Shudan Zhou and Robert Morris, both partners at Norton Rose Fulbright US LLP, will discuss the following topics related to clients that have nexus with both the US and China:
1. Big picture and recent trends
2. How the proposed US Tax Bill may impact Chinese (and other international) clients
3. Debunking Myth #1: It’s not all about foreign grantor trust planning; it’s about what happens afterwards
4. Debunking Myth #2: Asset protection is not all about trusts
5. Debunking Myth #3: Underfunded IRS makes life easier
6. Case studies
Shudan Zhou, a Partner at Norton Rose Fulbright US LLP in their New York office, counsels high net worth individuals, trustees, and financial institutions on the US tax implications of wealth transfer strategies, with an emphasis on international income and estate tax planning. She has substantial experience advising clients on all aspects of FATCA and CRS as well as various withholding tax and disclosure regimes. Shudan frequently advises clients on the US tax consequences of expatriation from and immigration to the United States, and of US inbound and outbound investment structures. Shudan also advises on the creation, administration and governance of offshore trust structures. She is a member of STEP and has spoken at a number of conferences in the US.
Robert Morris, a Partner and Co-Head of US Tax at Norton Rose Fulbright US LLP out of their Houston office, co-leads the tax practice and represents clients in tax controversy matters, which includes IRS examinations, IRS fast track mediations, IRS appeals, litigation in the United States Tax Court and Federal district courts, and before the IRS competent authority office. Rob also regularly represents clients in state tax disputes, transfer pricing issues, tax sharing agreement disputes, and matters involving allegations of tax fraud and potential criminal tax charges. Although Rob has appeared in many notable court cases, the majority of disputes that Rob has handled were successfully resolved administratively with the IRS and never became public.