Moore & Bruce, LLP advises U.S., non-U.S. and “multiple nationality” families with respect to trust and estate planning. The context is often not merely planning for the death of an individual or couple but how they will live their lives—life planning. The applicable rules are especially complicated when applied to two or more jurisdictions. As a practical matter, this subject overlaps both tax and immigration and nationality law.

One of the skills required is the ability to convey a range of technical information and common sense points to clients. Sometimes this is made more difficult by cultural differences. The attorneys at the Firm, by virtue of years of experience, are able to do this effectively. U.S. taxation of foreign (i.e., non-U.S.) trusts is a particular specialty. The Firm advises a number of foreign banks and trust companies with respect to these subjects.

We advise individuals that may wish to renounce their U.S. citizenship (these are often individuals that are dual nationals by birth) or to immigrate to the U.S., becoming U.S. resident aliens for income tax purposes, sometimes U.S. residents (domiciliaries) for estate and gift tax purposes) and sometimes U.S. citizens.

In addition to providing U.S. individuals and families with traditional will and trust drafting services, we have recently been engaged in the following projects:

• Redrafting a series of Bermuda trusts to conform to recent changes in the manner in which U.S.-resident beneficiaries are taxed on trust distributions.
• Creating a family gifting program, including family limited partnerships, to maximize the annual gift tax exclusion.
• Structuring significant lifetime charitable gifts to balance income requirements and estate and income tax reduction strategies.
• Advising a non-U.S. private bank and one of its European clients on mitigating U.S. income and estate tax on holdings, through a U.S. public company, of U.S. real property subject to the Foreign Investment in Real Property Tax Act (FIRPTA) rules.
• Estate planning for a U.S. family that controls a group of Australian companies.
• Estate planning for a U.S. and German couple with holdings primarily in Germany.
• Advising as to catching up with filing of U.S. tax returns and Foreign Bank Account Reports and renunciation of U.S. citizenship by an “accidental American” who was born in the U.S. to Swiss parents but never lived in the U.S. after age 9 months.

• Counseling a U.S. “long-term” resident as to the relinquishment of her U.S. “greencard”.