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International Estate & Tax Planning 2017


Speaker(s): Amy E. Heller, Barbara T. Kaplan, Beth D. Tractenberg, Carey Jones Perry, Jr., Daniel Price, Dean C. Berry, Gary R Lee, Karen A. Brodsky, Michael Rosen-Prinz, Steve Trow, Thomas J Handler, J.D., P.C., Veronica F. Hyman-Pillot
Recorded on: May. 22, 2017
PLI Program #: 185259

Veronica Hyman-Pillot has been employed by IRS Criminal Investigation for 32 years.  She started her career in January 1985 as a Co-op student in the Detroit Field Office while working on her degree from Michigan State University.  She remained in the Detroit office as a Special Agent until January 2003 at which time she was promoted to a Supervisory Special Agent in Pontiac, Michigan where she remained until October 2007.  From October 2007 – October 2010, Veronica worked as a Senior Analyst in IRS Criminal Investigation International Operations where she was the desk officer for numerous foreign posts and served on several International Working Groups. From October 2010 through December 2012, Veronica was the Assistant Special Agent in Charge of the Atlanta Field Office.  In January 2013, Veronica became the Special Agent in Charge of the Atlanta Field Office.  Veronica currently serves as the Acting Deputy Director of the Office of International Operations in Washington, DC.


Amy Erenrich Heller’s practice encompasses a wide range of domestic and international tax and estate planning matters. She has particular experience advising international families making inbound U.S. investments and U.S. families with holdings abroad. Ms. Heller also counsels clients on business succession planning and on issues that may arise in connection with M&A or corporate finance transactions.

Ms. Heller is an adjunct professor at the New York University School of Law, where she teaches Income Taxation of Trusts and Estates.

Ms. Heller is a fellow of the American College of Trust and Estate Counsel. She serves as vice chair of the International Estate Planning Committee and has served as chair of the Generation Skipping Transfer Tax Committee of the American Bar Association Section of Real Property, Trust and Estate Law. She also is the American Bar Association Advisor to the Uniform Law Commission Trust Decanting Act and to the Uniform Law Commission on Divided Trusteeship. In addition, Ms. Heller has served as a member of executive committee of the Tax Section of the New York State Bar Association and has served as co-chair of the Tax Section’s Committee on Estates and Trusts.

She is a frequent speaker and author on tax and estate planning topics for professional organizations and publications, including the Journal of Taxation, the Journal of Regulatory Economics, the Heckerling Institute on Estate Planning and the American Law Institute.

Ms. Heller has been ranked annually in Chambers USA since 2010 and in the inaugural Chambers High Net Worth Guide in 2016. She previously was nominated for the Chambers USA Up and Coming Wealth Management Lawyer of the Year award. She also has been named as a Euromoney Leading Woman in Business Law annually since 2014.

Education

LL.M., Tax Law, New York University School of Law, 2008

J.D., Harvard Law School, 2002 (cum laude)

B.A. Harvard University, 1997 (magna cum laude; Phi Beta Kappa)

Bar Admissions

New York


Barbara T. Kaplan is a shareholder of Greenberg Traurig, co-chair of the Global Tax Practice and chair of its New York Tax Practice.  Her practice focuses primarily on tax controversies, both civil and criminal, and litigation in courts with jurisdiction over federal, state and local tax disputes.  She is a Fellow of the American College of Tax Counsel, is consistently listed in Best Lawyers in America, is ranked by Chambers, is listed among the top 50 female lawyers in New York City by Super Lawyers and is listed in Euromoney’s 2014 and 2017 Guide to the World’s Leading Women in Business Law.  In 2016, Ms. Kaplan received the Euromoney Women in Business Law Award for Best in Tax Dispute Resolution.  In 2019, she was included in Crain’s 2d Annual Notable Women in Law list.  She also is listed in the 2018 Legal 500 Guide to Outstanding Lawyers in the category of “Tax – U.S. tax – contentious.”

She is admitted to practice in New York State, the United States Tax Court, the United States Court of Federal Claims, the United States District Courts for the Eastern and Southern Districts of New York, the United States Court of Appeals for the Ninth Circuit and the United States Supreme Court.  She was a senior trial attorney for the Internal Revenue Service prior to entering private practice.  She is a graduate of the University of Wisconsin (B.A.), Northwestern University (M.A.), Brooklyn Law School (J.D.) and the New York University School of Law (LL.M - Taxation).

Ms. Kaplan is a frequent speaker and writer for numerous tax conferences and publications, including Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures, and Other Strategic Alliances (Practising Law Institute, 1995 to the present), Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings (Practising Law Institute, 1998 to the present), the American Bar Association’s Annual National Institute on Criminal Tax Fraud (2010 to the present), New York University’s Tax Controversy Forum and Practising Law Institute’s International Estate & Tax Planning program (2011 to 2017), Practising Law Institute’s Nuts and Bolts of Tax Penalties (2013 to 2017), among others.  Ms. Kaplan is an active member of the Tax Sections of the American and New York State Bar Associations, The Association of the Bar of the City of New York, The American Association for Justice, and the National Association of Criminal Defense Lawyers.


Beth D. Tractenberg guides high-net-worth individuals, families, and fiduciaries in international and domestic estate planning, contested matters, estate administration, the creation and advising of exempt organizations, and drafting and negotiating prenuptial agreements. Beth, who heads Steptoe’s Private Clients practice, provides comprehensive tax, personal, and business advice to families, working closely with their family offices and other advisers. Drawing on her tax and trusts and estates experience, Beth serves clients as a personal and family adviser on numerous business, management, and related personal issues, including issues involving real estate and business holdings in the United States and abroad. Beth has extensive experience advising international clients on cross-border and pre-immigration planning, gifting, estate planning, and other tax issues. She frequently assists in resolving business disputes and sensitively guides succession planning across generations of family members. Clients value her ability to successfully balance intra-family dynamics with efficient tax planning, and The National Law Journal recently named her to its “Trailblazers in Divorce, Trusts & Estates” list.

Beth also counsels private equity and hedge fund managers on estate planning issues and has significant experience advising clients on estate planning opportunities that arise in connection with both the formation and sale of closely held businesses. In addition, Beth has created scores of nonprofit entities, obtaining tax-exempt status for each. As a board member of numerous nonprofits, Beth applies her wealth of insight to advise charitable entities on matters such as compliance and fundraising.

Beth is recognized as a thought leader in the realm of estate planning, and is frequently called on to present to groups such as the International Tax Planning Association, American Law Institute, Practising Law Institute, the Trusts and Estates Law Section of the New York State Bar Association, the Philadelphia Estate Planning Council, National Financial Partners, and the New York Society of Securities Analysts. She received her J.D. from New York University School of Law and her B.A. from Wesleyan University.


Daniel N. Price is an attorney with the Office of Chief Counsel of the Internal Revenue Service (SB/SE Division) in Austin, Texas. His practice focuses on international individual compliance matters. He assists revenue agents handling complex cases including cases involving tax fraud and willful FBAR violations. And Dan advises the IRS on national issues relating to Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures. His role in these special compliance initiatives includes planning, developing, and writing FAQs for public guidance, speaking at practitioner events, training and advising IRS personnel, developing job aids and templates, and much more.

Dan received an undergraduate degree in accounting, summa cum laude, from the University of Texas at San Antonio, and a masters degree in accounting from Trinity University. Dan received his J.D., with honors, from the University of Texas School of Law. During the first year of law school, Dan passed the Uniform CPA exam (not licensed as a CPA).

For additional details on Dan’s professional background, please see his profile on LinkedIn.


Karen is the Deloitte Tax Global Private Client Leader as well as the Private Wealth Tax Leader for the U.S. East Region.

Karen specializes in serving international and domestic private clients, including income, estate and gift tax planning and compliance for domestic and cross-border families and their family offices, domestic and foreign trust income taxation, taxation relating to individual expatriation, and related information reporting.

Karen is a regular speaker at external tax and estate planning seminars and has authored and co-authored numerous professional articles. Karen is Chair of the AICPA Foreign Trust Task Force and a member of the AICPA Expatriation Task Force. Karen also develops and delivers numerous internal tax training programs.

Karen earned her LLM in Taxation from Georgetown University Law Center, JD from Brooklyn Law School, and both a BBA and MBA in Accounting from Pace University. Karen is a CPA and a member of the New York State Bar.


Mr. Handler is an advanced planning attorney focused on the analysis and structuring of sophisticated estate plans and family offices, and handling taxation and business planning issues for business owners, executives, professional athletes, celebrities and family offices. He has extensive experience in the analysis, design and implementation of domestic and international business planning, financial and estate planning, asset protection, family office compliance and advanced tax planning strategies. Mr. Handler is a managing partner in Handler Thayer, LLP, where he chairs the firm's Advanced Planning & Family Office Practice Group.

His experience includes tax controversy, estate contests, tax litigation, public accounting and corporate and foundation directorships. He is active in Chicago Bar Association activities including its Taxation and Trust Law committees, and has authored numerous professional articles. He has lectured extensively both nationally and internationally at wealth industry, professional and family office educational conferences. Mr. Handler created the Asset Protection Profile™ and Stealth Prenup™ in addition to other proprietary strategies for affluent families and family offices.

Mr. Handler has been named to the Wealth Strategies Design Team comprised of fifteen of the top wealth planners in the U.S., to the Citywealth Global Leaders List of Top Wealth Planning Attorneys, to Who’s Who in American Law and Who’s Who in America. Illinois Leading Lawyers named Mr. Handler one of the Top Lawyers in the areas of Closely and Privately Held Business Law and Trusts, Will and Estate Planning Law. In 2016 he was ranked in the Citywealth Global Leaders List of Top 100 Lawyers in the U.S. He also won the Excellence in Estate Planning Award and was again named to Leading Lawyers and Lawyers of Distinction. In 2015 he was named International Wealth Planner of the Year and Wealth Planning Gamechanger Lawyer of the Year in addition to receiving the Michael J. Brink Wealth Industry Leadership and Service Award.

He earned a Bachelor of Sciences in Accountancy degree from the University of Illinois at Urbana-Champaign and a Juris Doctor degree, Law Review, from DePaul University College of Law in Chicago, Illinois. Mr. Handler is a recognized thought leader in the advanced planning and family office marketplaces who has been quoted in the Wall Street Journal, Chicago Tribune, New York Times, Worth Magazine, Financial Times, Barron's, Christian Science Monitor, Family Office Review, Las Vegas Review-Journal, Chicago Sun-Times, Structured Products Magazine, ABA Journal, National Law Journal, Crain’s Chicago Business, Derivatives Weekly, Family Wealth ReportWealth Manager Magazine and other publications. He has appeared as an expert commentator on numerous radio and television programs.


Position/Title:  Partner, Head of Private Client Group Firm: Shearman & Sterling LLP

Primary Areas of Practice:  Private Clients

Law School:  University of North Carolina School of Law, J.D. Graduate School: New York University Law School, LL.M. in Taxation

Work History:  Shearman & Sterling LLP since 1987

Professional Memberships:  Society of Trusts & Estates Professionals


Dean Berry, Chair of the firm's Private Client Group, assists clients in developing and implementing tax-efficient strategies for the management and transfer of private wealth, with a focus on complex cross-border trust and estate planning. He works with attorneys, accountants, investment advisers and fiduciaries from around the world to provide coordinated advice to international high net worth clients.

Dean’s clients include individuals with family connections to multiple jurisdictions, individuals married to non-U.S. citizen spouses, U.S. beneficiaries of foreign trusts, U.S. shareholders of foreign corporations and foreign persons owning U.S. assets.  He also advises and assists philanthropic donors in making charitable gifts through private foundations, donor-advised funds, and charitable split-interest trusts, and counsels charitable organizations on corporate and tax matters. 

Dean is an Academician of the International Academy of Estate and Trust Law, and a member of the American Bar Association (Section on Real Property, Probate and Trust Law) and the New York State Bar Association (Trusts and Estates Section). He received his J.D., cum laude, from Harvard Law School, where he was an editor of the Harvard Law Review, and an LL.M in Taxation from the New York University School of Law.


Gary Lee heads the third Party Advisor group at Sterling Resources, Ltd., working with attorneys, accountants, and family offices to serve their high net worth clients with innovative life insurance solutions for estate planning and closely held corporation needs.  He is a lawyer with an LLM in Taxation and a CPA.  Prior to joining Sterling, Gary was National Director of Insurance Consulting Services with Deloitte & Touché for over a dozen years.  He is a published author of a life insurance BNA portfolio and has contributed articles to various tax publications.  He is also a speaker at tax forums across the country and in Europe focusing on both domestic and international life insurance planning opportunities.


Michael Rosen-Prinz is a partner in the Private Client Practice Group at McDermott Will & Emery LLP in Los Angeles. He works closely with individuals and families on matters involving wealth transfer, family governance, and business succession. Michael devotes a substantial portion of his practice to international estate and tax planning, including advising clients on issues related to foreign trusts and entities, structuring foreign investment in the United States, and planning for individuals moving to and from the United States. Michael has lectured and written on topics related to international estate planning and taxation as well as planning for digital assets. Michael received a JD from the University of California, Berkeley School of Law, and a BA from University of California, Santa Barbara.


Steve Trow has over 30 years of experience in U.S. immigration and citizenship law.  He is particularly interested in the intersection of immigration law and tax law.  He advises high net worth clients and their professional advisors on integrating immigration planning with tax planning; obtaining U.S. visas, green cards and citizenship; and surrendering U.S. green cards and citizenship.  Steve is listed in Best Lawyers in America, Chambers USA, Super Lawyers, and Who’s Who Legal: Corporate Immigration.  He is a graduate of Cornell Law School and a member of the District of Columbia Bar.