Navigating the Next Chapter: Estate Tax Mitigation and Wealth Preservation Strategies for Exiting Australia/US Entrepreneurs

Some of the relevant issues that were addressed include:

Estate Tax Mitigation Strategies

• Domicile Considerations: Understanding how domicile affects U.S. estate tax liability for Australian residents with U.S. assets, and strategies to manage domicile status.
• Navigating the $13.99M US estate tax exemption (IRC §2010) for non-domiciled Australians and Utilizing Foreign Tax Credits: Exploring how tax treaties between the U.S. and Australia can help reduce estate taxes by allowing credits for taxes paid in Australia, even though Australia does not have estate taxes.
• Irrevocable life insurance trusts (ILITs), GRATs, and CRTs in cross-border contexts
• Pitfalls of Australian testamentary trusts under US tax code
• Asset Protection Trusts: Examining the use of asset protection trusts in both Australia and the U.S. to shield assets from creditors and potentially reduce estate tax liabilities.
• Impact of U.S. Tax Reform: Addressing potential changes in U.S. estate tax laws and how they might affect Australian business owners with U.S. assets.

Post-Exit Wealth Preservation

• State-specific residency planning: (No-income-tax jurisdictions vs. California’s 13.3% rate). Beyond California, discussing other U.S. states with favorable tax environments for wealth preservation, such as Florida or Texas
• Philanthropic Strategies Beyond DAFs: Exploring other philanthropic vehicles, such as charitable remainder trusts (CRTs), that can provide tax benefits while supporting charitable causes
• Tax-Efficient Investment Strategies: Discussing investment strategies that minimize tax liabilities in both the U.S. and Australia, such as using tax-loss harvesting or Direct indexing
• Cross-Border Retirement Planning: Exploring how to optimize retirement savings across borders, including the use of U.S. IRAs and Australian superannuation funds
• International Asset Allocation: Considering how to allocate assets globally to maximize returns while minimizing tax exposure in both countries.

We hope you enjoy!