:Module One
Personal Financial Planning, Estates, and Risk Management
Offshore Private Placement Life Insurance
a) Introduction to Offshore Variable Life Insurance
b) Offshore Holding Structures
c) Asset Protection Benefits
d) Investment Management Benefits and Flexibility
e) Tax Benefits
f) Liquidity
g) The IRC 953 (d) Election
h) Diversification and Investor Control
i) Due Diligence Requirements
j) Gathering Information
k) Prequalification and Placing the Offshore Policy
The Law of Trusts and Fiduciary Obligations
a) Uses of trusts
b) Distinction between a trust and a power
c) Discretionary trusts
d) Certainty, the beneficiary principle and purpose trusts
e) Charitable trusts
f) Unincorporated associations and pension funds
g) Secret trusts and mutual wills
h) Resulting and constructive trusts
i) Breach of trust. Breach of fiduciary duty
j) Tracing, and strangers to the trust
k) Appointment and removal of trustees
l) Duties of trustees
m) Termination and variation of trusts
:Module Two
INTERNATIONAL ESTATE PLANNING
Income, Gift and Estate Taxation and Planning
Taxation of U.S. citizen residents or domiciliary
a) Estate taxation
b) Gift taxation
c) Generation-skipping transfer taxation
d) Marital deduction planning for citizens and residents with non-citizen spouses
Asset protection trusts for U.S. persons
a) Tax compliance and tax reporting requirements
b) Penalties for failure to file
Charitable contribution deduction under U.S. tax laws
Taxation of non-residents and non-domiliciaries
a) Income taxation
b) Estate taxation
c) Gift taxation
Income, gift and generation-skipping transfer taxation of non-resident aliens
a) Passive investments
b) Active Trade or business operations
c) Foreign Investment Real Property Tax Act (FIRPTA)
d) Use of foreign corporations to avoid FIRPTA
e) Conflict of Laws
f) Marital deduction planning
g) Trusts and foundations under civil law jurisdictions
h) Asset protection trusts for foreign persons
i) Reporting and disclosure requirements for foreign persons
j) Succession Planning: Planning a Family and Business Legacy
:Module Three
Service Approach vs. Transactional Approach - Client and Advisor Benefits.
How to Switch From a Product-Oriented Salesperson to a Fee-Based Advisor
a) Family Interviews
b) Fact and Feeling Finding. How to determine family member wants, needs and expectations through family interviews
:Group Exercise
:Module Four
Charitable Planning for the Financial Advisor
a) Public vs. Private Foundations
b) Charitable Intent
c) Charitable Tax Forms
d) Capital Gain Bypass
e) Charitable Instruments
f) Charitable Life Insurance
g) Gift Annuities
h) Charitable Trusts
i) What to do for the non-U.S. resident
j) Foreign Trusts
k) Foreign Foundations
l) Jurisdiction
m) Equitable Distribution
n) Prenuptial Agreements
o) International Planning
:Module Five
International Anti-Avoidance and Tax Treaties
:Group Exercise
Final Examination
The final examination will be in a Multiple-Choice format