On May, 28, 2021, Caroline D. Ciraolo participates in a panel entitled “Hot Topics on Dealing with International Taxpayers and Tax Treaties” at the California Lawyer’s Association Annual Estate and Gift Tax Conference.
Description: The panel will discuss tips and traps for international income and estate tax practitioners when using tax treaties to address an international taxpayer’s federal income, gift and estate tax planning issues. The panel will provide insights on treaty-shopping to maximize an international taxpayer’s US estate tax exemption and use of competent authority mechanism to resolve the “grey areas”, and issues that arise when dealing with Australia, Canada, and the PRC. The panel will also discuss model treaty provisions in US bilateral tax treaties and tax information exchange agreements that are used by tax authorities to request tax return information and tax collection assistance, including frequency of requests for information among tax authorities, the procedure in the U.S. for making requests and processing requests received, grounds and applicable procedures for challenging such requests under United States v. Powell, 379 U.S. 48 (1964), and its progeny, and recent related litigation.
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