Key Estate Planning Concepts for International Clients

Patrick J. McCormickK&D associate, Patrick J. McCormick, authored the below article, “Key Estate Planning Concepts for International Clients”, which will appear in the forthcoming June 2017 issue of Estate Planning, a nationally recognized journal published by Thomson Reuters, and again in a Summer 2017 issue of the Journal of International Taxation, also published by Thomson Reuters. Mr. McCormick specializes in the areas of international taxation and tax compliance.


 

Estate Planning International ClientsIn recent years, both the IRS and practitioners have vastly increased their focus on international compliance issues. Service-authorized programs for retroactive offshore disclosures have generated more than $10 billion of revenue for the federal government. Practitioners have been inundated with requests by clients to participate in retroactive disclosure programs (and, very possibly, could soon be inundated with requests from clients to fight FBAR assessments made by the Service against individuals who did no voluntarily come forward).

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