Estate Planning and Your Plan B: A Q&A with Schiff Sovereign Total Access Members
Earlier this month, Milan Solarz-Patel, J.D., LL.M. (Taxation), attended the Schiff Sovereign Total Access Conference in Panama City on behalf of Auric Private Client Advisory LLC. As described in our notes from the Total Access Conference, the weekend covered residency, citizenship, banking, real estate, and precious metals. One important topic did not fit into the program: estate planning and asset protection.
Schiff Sovereign has invited Milan to address that topic. On Wednesday, September 30, 2026, at 7:00 p.m. Eastern, he will join Total Access members for an interactive call. The session will be a conversation and Q&A rather than a formal presentation.
Why Estate Planning Belongs in a Plan B
A Plan B creates options: a second residency, a second passport, and accounts and property abroad. Each option also changes how wealth passes to the next generation. A U.S. citizen remains subject to U.S. estate and gift tax on worldwide assets, wherever he or she lives. A new country of residence may impose its own inheritance tax or forced-heirship rules. Assets held in several jurisdictions can fall under more than one set of laws at death. Without coordination, a structure built for flexibility can become costly and difficult for heirs to settle.
Topics for the Call
How estate planning fits into a broader Plan B strategy
Types of trusts, how each works, and when each makes sense
Federal estate and gift tax, the lifetime exemption, and annual gifting
Retirement accounts: existing protections and remaining vulnerabilities
Assets held across multiple jurisdictions
How residency, citizenship, and domicile affect estate and tax planning
Building flexibility into an estate plan as laws and circumstances change
Common mistakes and overlooked issues
Passing wealth efficiently to children and future generations
The 2026 Numbers
The One Big Beautiful Bill Act, signed on July 4, 2025, removed the scheduled reduction of the federal exemption and set it at $15 million per person for 2026, indexed for inflation thereafter. The 2026 exemption figures are as follows:
Lifetime estate, gift, and generation-skipping transfer tax exemption: $15 million per person ($30 million for a married couple)
Annual gift exclusion: $19,000 per recipient ($38,000 with gift-splitting)
Annual gifts to a spouse who is not a U.S. citizen: $194,000
Top rate on amounts above the exemption: 40 percent
Gifts above the annual exclusion are reported on Form 709.
Points Often Overlooked
For U.S. families pursuing a Plan B, the headline exemption is only part of the picture:
A spouse who is not a U.S. citizen does not qualify for the unlimited marital deduction unless assets pass through a qualified domestic trust (QDOT).
A nonresident who is not a U.S. citizen, including a former citizen, generally receives an exemption of only $60,000 for U.S.-situs assets, such as U.S. real estate and shares of U.S. companies.
Gifts and bequests from a covered expatriate to U.S. persons can be taxed to the recipient under Section 2801 of the Internal Revenue Code.
A trust formed abroad for asset protection brings annual U.S. reporting on Forms 3520 and 3520-A.
Join the Call
The call is open to Total Access members and non-members alike. Participants are encouraged to bring questions on trusts, estate taxes, asset protection, or international planning. Questions may also be sent in advance to access@schiffsovereign.com.
Date: Wednesday, September 30, 2026
Time: 7:00 p.m. Eastern (6:00 p.m. Central)
Zoom link: https://us02web.zoom.us/j/87606177289?pwd=hjSFl6n4ODwNBfi4Bw698L3nvNE4fT.1
Meeting ID: 876 0617 7289
Password: 603962
A follow-up post will summarize the main questions and themes from the discussion.
If you are a U.S. person with assets or family in more than one country, contact Auric Private Client Advisory LLC to review how your estate plan and your U.S. reporting work together: https://www.auricllc.com/contact
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