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International Estate & Tax Planning 2019


Speaker(s): Andrew S. Auchincloss, Bruce Zagaris, Dean C. Berry, Dina Kapur Sanna, Ellen K. Harrison, Megan R. Worrell, Michael W. Galligan, Scott E. Fink, Shelly Meerovitch
Recorded on: May. 6, 2019
PLI Program #: 250664

Andrew Auchincloss focuses his practice on estate and investment planning strategies under U.S. law for U.S. and non-U.S. individuals and families.  He represents wealthy individuals and families, tax-exempt organizations, banks, and trust companies, family offices and private trust companies and other clients in a broad range of substantive areas.

Andrew’s international planning experience has included a wide array of situations and solutions, including the representation of global families in the structuring of their U.S. and international wealth; representing U.S. bank and financial services firms in their dealings with international private clients; and assisting in the litigation of probate disputes with international dimensions, among other matters from all over the globe.

Andrew’s domestic planning experience includes working with family offices for significant U.S. families; working with U.S. banks and trust companies in the context of fiduciary and tax planning issues; representing a major American novelist; and assisting in significant tax and estate related litigations, including cases involving will constructions and a major case on the limits of a state’s power to tax the income of personal trusts.

Prior to joining the firm in 2016, Andrew was a partner at the global law firm Sidley Austin LLP.  Prior thereto, Andrew was a director in the Wealth Management Group at Bernstein Global Wealth Management (Alliance Bernstein), the investment management firm.  There he conducted research, and assisted the firm’s clients, in the areas of international and domestic planning.  Prior to Bernstein, he practiced at White & Case LLP for 18 years, as a partner from 2000 to 2007, representing international and domestic families, charities and financial institutions in the context of estate planning, tax and fiduciary law.

Andrew received a B.A. in 1986 from Yale University and a J.D. from the University of Virginia School of Law in 1989. Strong leadership on behalf of clients has earned Andrew recognition in the 2016 edition of Chambers High Net Worth, Who’s Who Legal: Private Client 2016 and Best Lawyers in America.

Andrew also currently serves as Chairman of the Trusts, Estates and Surrogate’s Court Committee of the New York City Bar Association.  Andrew has been elected a fellow of the American College of Trusts and Estates Counsel (ACTEC).


Dina Kapur Sanna has over 20 years of experience in advising U.S. and non-U.S. taxpayers on wealth management structures which accommodate multi-jurisdictional tax and legal considerations. Her practice involves foreign trusts, pre-immigration and expatriation planning, planning for the purchase of U.S. property by non-U.S. persons and compliance with tax and reporting obligations for those with overseas interests in foreign accounts, corporations and trusts.

Dina is recognized as a leading international estate planning attorney by Chambers HNW* (Chambers & Partners), Chambers Global*, Private Client Global Elite (ALM Media Properties, LLC), and The International Who's Who of Private Client Lawyers. In the 2018 edition of Chambers HNW, they note that Dina advises on a full range of wealth management matters, including trusts and immigration planning for affluent families. They quote one source who said, "She is so responsive, it's unbelievable. There is no question she can't answer in 24 hours. She's also very passionate and very good at explaining complicated laws and regulations to clients, especially in tax." Chambers HNW quote another interviewee who enthused, "I think she is outstanding. I have always found her to be extremely bright, practical and a nice person with whom to work."

Dina is a frequent speaker at estate planning seminars around the world. She has written numerous articles that appear in legal periodicals in the U.S. and abroad.

Dina is a fellow of the American College of Trust and Estate Counsel (ACTEC) and a member of its International Estate Planning Committee. In addition, she is an Academician of The International Academy of Estate and Trust Law. She also holds a leadership position as a member of the Firm's Executive Board. 

 


Ellen K. Harrison advises clients on a broad range of tax issues, including estate planning and administration, tax controversies, and income, gift and estate tax planning for individuals, businesses and charitable organizations. She has significant experience drafting wills, trusts, powers of attorney, prenuptial agreements and buy-sell agreements, as well as a broad range of corporate documents and family partnership agreements. Her tax controversy and litigation experience includes Internal Revenue Service (IRS) audits, IRS appeals, refund claims and US Tax Court litigation.  Previously, Ellen was an adjunct professor at Georgetown Law Center.

EDUCATION

  • Harvard Law School, JD, cum laude, 1971
  • University of Michigan, BA, with highest honors, 1968

ADMISSIONS

  • District of Columbia
  • Maryland

RECOGNITION

  • The Best Lawyers in America, 1997-2019, Trusts and Estates and Litigation- Trusts and Estates
  • Best of the Best USA
  • Chambers High Net Worth 2016 and 2017, Band 1, DC, Private Wealth Law and USA, Private Wealth: Eastern Region
  • Citywealth Leaders List, 2018
  • Guide to the World’s Leading Trusts & Estates Lawyers
  • PLC Which Lawyer?
  • Super Lawyers
  • Washington’s Top Lawyers

COMMUNITY

  • International Academy of Trust and Estate Lawyers, President
  • University of Miami School of Law, Heckerling Institute on Estate Planning, Advisory Committee
  • American College of Trust and Estate Counsel, liaison to th AICPA, as well as past regent and past chair of the International Estate Planning Committee and the Washington Affairs Committee
  • American Bar Association, Section on Real Property, Trust and Estate Law, serves as liaison to the American Institute of Certified Public Accountants (AICPA) and as co0chair of the Trust and Estate Committee on Government Submissions


Megan R. Worrell is the Vice Chair of the Duane Morris’ Private Client Services Practice Group, and head of the group's International Practice division. She practices in the area of U.S. and international tax and wealth transfer planning, specifically assisting clients with cross-border issues to develop tax-efficient estate plans. Her work involves foreign trusts, pre-immigration and expatriation planning, planning for the purchase of U.S. property by non-U.S. persons, asset transfers, beneficiary conflicts, and compliance with federal and state estate, gift, inheritance and income tax returns. She also has extensive experience with clients who have made voluntary disclosures to the IRS, including clients disclosing overseas accounts and complying with reporting obligations for those with overseas interests.

Prior to and while attending law school, Ms. Worrell worked as a tax consultant at Arthur Andersen and Deloitte & Touche.

Ms. Worrell is admitted to practice in New York and New Jersey, and is licensed in Pennsylvania as a certified public accountant. She is a 2003 graduate of Fordham University School of Law, where she was a member of the Fordham International Law Journal, and a graduate of Widener University (M.S., Taxation, summa cum laude) and Salisbury State University (B.S., Accounting, summa cum laude). 

 


Michael W. Galligan is a partner in the Trusts & Estates Department at Phillips Nizer LLP, where he practices primarily in the areas of domestic and international estates and trusts, U.S. and cross-border estate and income tax planning, private international law, and immigration.

Mr. Galligan concentrates his practice in complex U.S. and international estate planning and the administration of U.S. and non-U.S. trusts, estates and other wealth transfer and wealth preservation vehicles. In addition to clients who are U.S. citizens and residents with family members and property holdings located only in the United States, his clients include U.S. citizens and residents with property holdings abroad; non-U.S. citizens and residents who own property and invest in the United States; families whose members are citizens and residents of different countries and often own property in different countries; non-U.S. persons planning to become U.S. residents; and U.S. citizens and residents leaving the United States permanently or temporarily. He also represents individual and corporate fiduciaries in connection with these matters. With the assistance of qualified counsel in the relevant jurisdictions, Mr. Galligan has worked on cross-border wealth transfer, trust and succession projects involving well over thirty countries worldwide.   

In connection with the international aspect of his practice, Mr. Galligan also advises clients on immigration law and directs services to clients who need specialized assistance in obtaining or maintaining legal immigration status in the United States as well as close coordination of their immigration goals with their tax and estate planning objectives.

Mr. Galligan is a Fellow of the American College of Trust and Estate Counsel, an Academician of the International Academy of Estate and Trust Law and The Society of Trust and Estate Practitioners (STEP).  He is a former Chair of the International Section of the New York State Bar Association (NYSBA), and is a member of the American Society of International Law, the American Immigration Lawyers Association, and the New York International Arbitration Center.

Since 2016, Mr. Galligan has been ranked by Chambers and Partners in Chambers HNW (High Net Worth), a ranking of high net worth legal practitioners worldwide.  He has been selected as one of The Best Lawyers in America© since 2009, and has appeared in the Super Lawyers® -- Metro New York edition since 2006.

Mr. Galligan is a graduate of the Columbia University Law School, where he was an Editor of the Columbia Law Review and a Harlan Fiske Stone Scholar.  He received his B.A. from the University of San Francisco, holds a Doctorate of Philosophy from the Yale University Graduate School and a Master’s Degree in International Affairs from the Columbia University School of Public and International Affairs.

 

 


Scott E. Fink is a shareholder at Greenberg Traurig, LLP who focuses his practice on civil and criminal federal and state tax controversies and litigation. He represents corporations, partnerships, estates and individuals before the Internal Revenue Service, and state and local tax authorities in examinations, collection problems, administrative appeals, and in court. Scott has been consistently recognized in The Legal 500 United States for tax controversy since 2014 and has also been recognized as a “Rising Star” by New York Metro Super Lawyers. In addition, Scott has received the Chief Counsel Cube Award and the Performance Award, from the IRS, Office of Chief Counsel. Scott received his LL.M. in Taxation from New York University School of Law, his J.D. from Benjamin N. Cardozo School of Law, Yeshiva University, and his B.A. from the University of Michigan.


Shelly Meerovitch, JD, is a Director and Senior Vice President in the Wealth Strategies Group in Bernstein’s New York office. She brings over 20 years of expertise in international and domestic trusts and estate issues. Before joining Bernstein, Shelly was a partner of the law firm Katten Muchin Rosenman LLP in New York. She focuses on international planning, and works with our high-net-worth clients and their professional advisors to optimize structures for tax-efficient investment in the US, wealth transfer to US beneficiaries, and the creation and administration of global trusts. Shelly is a member of the State Bar of New York, and has written on many pre-immigration planning and cross-border tax issues. She is a member of the London-based Society of Trusts and Estates Practitioners (STEP). Shelly graduated Phi Beta Kappa from the University of California Los Angeles with a BA in psychology, summa cum laude, and earned a JD from Columbia Law School.


Bruce Zagaris is a partner in the Washington, D.C. firm of Berliner, Corcoran & Rowe LLP. Mr. Zagaris' practice includes tax controversy work, including representing individuals and entities in offshore voluntary disclosure applications, audits, and criminal tax investigations, such as exchange of information and evidence gathering. He has also represented many governments and international organizations. The work has included negotiating tax treaties, advice on FATCA IGAs, bilateral investment treaties, mutual assistance in criminal matters treaties, and proposing and drafting financial products to attract investment.  Mr. Zagaris appears regularly as an expert witness in international tax, financial regulatory, and money laundering cases. He has authored and edited six books and many law review and other articles and frequently lectures. He has served as an Adjunct Professor at several law schools in and outside the U.S.  This semester he is an adjunct professor, teaching international white collar crime in the LLM on Wealth and Risk Management at Texas A&M Law Faculty.  His practice has involved advising clients in Latin America, especially Brazil, and the Caribbean.

His practice involves international evidence gathering, extraterritorial jurisdiction, extradition and INTERPOL, prisoner transfer matters, and advice on the Foreign Agents Registration Act (FARA).  He has been a registered agent under FARA since 1981.

Since 1985, he has served as editor-in-chief of the International Enforcement Law Reporter (www.ielr.com), a weekly and monthly journal on international enforcement law.

 



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.