No Nexus Required: Dangers of the Water’s Edge, and a New Paradigm for Cross-Border Clients (September 16, 2026)

Thu, 17 Sep 2026 00:00:00 GMT

No Nexus Required: Dangers of the Water’s Edge, and a New Paradigm for Cross-Border Clients

Wednesday, September 16 @ 5:00 pm | City Club of SF

Featured Speaker: Cynthia (Cindy) Brittain, ArentFox Schiff

* Please RSVP by September 14, 2026 to avoid a late registration fee.*

Topic

Generally, presentations about cross-border planning concentrate on cross-border taxation. However, playing outside of the water's edge may trigger harsh penalties related to the globalization of compliance. It's not just the U.S. FATCA regime that U.S. persons must navigate when traveling abroad. Certainly, tax, trust, and privacy planning laws vis-à-vis the U.S. and other jurisdictions can conflict. In the U.S., there is no required registration of domestic trusts. To require otherwise goes against the strong mandate of privacy most U.S. persons expect related to trust assets. It is understood that trusts have to pay U.S. income tax, but there is a strong sense of privacy related to the trust's beneficiaries and assets.

Those same principles are not always respected in other jurisdictions. Registration of trusts is mandated in many European countries, subject to harsh penalties for non-compliance. Registration is required for discretionary beneficiaries, regardless of whether or not that beneficiary ever receives a distribution.

The point of this presentation is to highlight required registrations and disclosures, along with conflicting laws that can negatively impact our clients. We'll discuss real-world scenarios where U.S. beneficiaries move and are almost immediately non-compliant, thus living within the danger beyond the water's edge!

Agenda

5pm - 6pm: Networking, cocktails, and appetizers
6pm - 7:30pm: Meeting and content presentation

Cost

$125 Members (pre-registered)*
$185 Guests (pre-registered)*

*An additional $25 fee applies if you register at the door.

About the Speaker

Cynthia (Cindy) Brittain

Cynthia ("Cindy") Brittain is a partner at ArentFox Schiff where she advises high-net-worth individuals, families, and family offices on sophisticated domestic and international wealth planning strategies.

With decades of experience in cross-border wealth planning, Cindy counsels clients on complex matters involving international estate and income tax planning, pre-immigration planning, business succession, family governance, charitable giving, private trust companies, and family office structures. Her practice also includes advising multinational families, entrepreneurs, and their advisors on navigating global regulatory and compliance issues while preserving and transferring wealth across generations. Cindy has extensive experience working with clients throughout Asia, Europe, the Middle East, and the Americas, including having lived and worked in both Hong Kong and London.

In addition to her legal practice, Cindy is a frequent speaker on international estate and tax planning and serves as an adjunct professor teaching International Estate Planning. She is recognized as a leading practitioner in private wealth law, including rankings in Chambers High Net Worth and Lawdragon 500 Leading Global Tax Lawyers.

CE Credit: This activity may be approved for continuing education credit by the State Bar of California and CFP Board. Certificates are provided after attendance.

Excused Absence: Members can request an excused absence in writing emailing us prior to the meeting.

Cancellations must be received three business days prior to the meeting.

Tax Audit Controversies with the IRS and FTB (November 18, 2026)

Thu, 19 Nov 2026 01:00:00 GMT

Tax Audit Controversies with the IRS and FTB

Wednesday, November 18 @ 5:00 pm | City Club of SF

Featured Speaker: Jonathan Feldhammer, Wendy Abkin and Kim Peterson

* Please RSVP by November 11, 2026 to avoid a late registration fee.*

Join us for our November member meeting.

Agenda

5pm - 6pm: Networking, cocktails, and appetizers
6pm - 730pm: Meeting and content presentation

Cost

$125 Members (pre-registered)*
$185 Guests (pre-registered)*

*An additional $25 fee applies if you register at the door.

About the Speakers

Jonathan Feldhammer

Jon D. Feldhammer is a Partner at Baker Botts LLP and serves as the Partner-in-Charge of the firm's San Francisco office. He represents businesses, high-net-worth individuals, family offices, and fiduciaries in complex federal and state tax matters, with a practice spanning tax controversy, international tax, estate and gift tax, and wealth transfer planning.

A former Senior Trial Attorney with the Internal Revenue Service, Jon brings a unique insider perspective to resolving sophisticated tax disputes and advising clients on tax compliance and planning. He has extensive experience representing clients before the IRS, the California Franchise Tax Board, and state and federal courts, including matters involving estate and gift taxation, international tax reporting, valuation, trusts and estates, and cross-border tax issues.

Jon is a recognized leader in tax litigation and controversy and is a frequent speaker on emerging tax and estate planning issues. He has been recognized in The Best Lawyers in America for Litigation and Controversy – Tax and is an active member of the American Bar Association, the San Francisco Estate Planning Council, and the California Lawyers Association.

Wendy Abkin

Wendy Abkin is the founder of Abkin Law PLC and a nationally recognized tax controversy attorney with more than three decades of experience representing businesses, individuals, fiduciaries, and tax-exempt organizations in complex federal and state tax matters. Her practice focuses on tax controversy and litigation, including audits, appeals, voluntary disclosures, criminal tax investigations, and civil tax disputes before the Internal Revenue Service, the California Franchise Tax Board, and other state and local taxing authorities.

Before entering private practice, Wendy served as a trial attorney with the IRS Office of Chief Counsel, where she litigated cases before the United States Tax Court. She has also served as a law clerk to judges of the U.S. Tax Court and is a former Chair of the Taxation Section of the State Bar of California. A frequent speaker and educator, Wendy has taught tax law as an adjunct professor at Golden Gate University and is widely recognized for her leadership in tax litigation and controversy. She has been honored by The Best Lawyers in America for Tax Law and has been recognized by Super Lawyers for her outstanding work in the field.

Kim Peterson

Kimberley (Kim) Peterson McGuire is a Director in Tax at Armanino, where she advises clients on tax controversy, tax procedure, IRS examinations, administrative appeals, and complex tax litigation. She brings more than 30 years of experience representing taxpayers in high-stakes federal tax matters and developing strategies to resolve complex disputes with the Internal Revenue Service.

Prior to joining Armanino, Kim served as a Tax Managing Director at Deloitte and spent more than 15 years with the IRS Office of Chief Counsel, where she held several senior litigation and advisory roles. She has been recognized multiple times with the IRS Chief Counsel Team Litigation Award and has been listed in the International Tax Review's Tax Controversy Leaders Guide and Women in Tax Leaders Guide.

In addition to her practice, Kim has taught in the Master of Science in Taxation program at San José State University, sharing her expertise in tax procedure and controversy with graduate students. She earned her J.D. from the University of Arizona James E. Rogers College of Law and her bachelor's degree from University of California, Berkeley.

CE Credit: This activity may be approved for continuing education credit by the State Bar of California and CFP Board. Certificates are provided after attendance.

Excused Absence: Members can request an excused absence in writing emailing us prior to the meeting.

Cancellations must be received three business days prior to the meeting.

San Francisco Estate Planning Council upcoming events

No Nexus Required: Dangers of the Water’s Edge, and a New Paradigm for Cross-Border Clients (September 16, 2026)

No Nexus Required: Dangers of the Water’s Edge, and a New Paradigm for Cross-Border Clients

Wednesday, September 16 @ 5:00 pm | City Club of SF

Featured Speaker: Cynthia (Cindy) Brittain, ArentFox Schiff

Topic

Agenda

Cost

About the Speaker

Cynthia (Cindy) Brittain

Tax Audit Controversies with the IRS and FTB (November 18, 2026)

Tax Audit Controversies with the IRS and FTB

Wednesday, November 18 @ 5:00 pm | City Club of SF

Featured Speaker: Jonathan Feldhammer, Wendy Abkin and Kim Peterson

Join us for our November member meeting.

Agenda

Cost

About the Speakers

Jonathan Feldhammer