*STEP LATAM Presentation* LATAM families with U.S. Children: Cross-Border Estate Planning

This presentation provides a concise roadmap for LATAM parents with U.S. children: it separates transfer-tax domicile from income-tax residency, defines U.S.-situs assets for estate, gift, and GST taxes, and weighs lifetime gifts by non-domiciliaries against basis step-up at death. It covers blockers and entity classification for U.S. assets, FIRPTA and liquidity for real estate, and core trust rules across grantor vs non-grantor and domestic vs foreign, including DNI/UNI, the throwback charge, and PFIC/CFC issues. A common design is a foreign grantor trust that converts at death into a domestic non-grantor trust via planned shifts in trustees, control, and governing law, with cautions on section 684 gain and section 2036(b). Post-death steps include PFIC clean-up, splitting by beneficiary residence, and aligning entity-to-trust-to-beneficiary distributions.

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