Brian P Tsu

HFM Trusts & Estates Partner Brian Tsu is a Young man of the American College of Trust and Estate Counsel and dual California Certified Legal Specialist.

Mr. Tsu represents loftier-net-worth individuals in the areas of domestic and international estate planning, related areas of taxation and closely-held family unit business organisation planning. He as well advises fiduciaries in complex trust and manor administrations, particularly when tax or cross-border problems are nowadays. His work includes:

International Estate Planning: Mr. Tsu advises individuals on the succession and tax aspects of planning for multinational families and their property interests. In particular, he counsels U.Southward. clients regarding the disposition of foreign property, with a particular accent on business holdings; in conjunction with local counsel, through integrated U.S. and foreign-based manor plans. Such plans consider and navigate the differences in marital, property, succession laws applicable to the client's multinational family and property interests. His international estate planning practice also provides succession and U.S. taxation planning communication to non-U.Due south. clients with respect to their U.S. investments and wealth transfers to U.South. beneficiaries. He also counsels clients on the repatriation of foreign trusts, foreign trust reporting, and estate/gift tax treaty analysis.

Taxation: Mr. Tsu also advises on all aspects of federal wealth transfer and fiduciary income revenue enhancement, as well as the wealth transfer aspects of California real holding tax. This includes the design and implementation of advanced wealth transfer techniques such as intentionally defective grantor trusts, intra-family installment sales, grantor retained annuity trusts, irrevocable life insurance trusts, qualified personal residence trusts and family limited partnerships/express liability companies. In addition to federal wealth transfer tax advice, he advises fiduciaries on California fiduciary income taxation and tax compliance. He regularly prepares and reviews gift and estate taxation returns and has successfully resolved manor and gift taxation audits and appeals.

Mr. Tsu also has pregnant experience advising on the wealth transfer and income tax consequences of trust decanting's, modifications, reformations, terminations, trust-to-trust transfers and beneficiary/fiduciary settlements. In addition to high-net-worth clients and fiduciaries, he has also brash certified public accountants, trust and estate litigators, and family police attorneys on tax matters related to trust and manor planning.

Closely-Held Family Business concern Planning: Mr. Tsu regularly advises clients on the organization, administration and succession of closely-held family businesses. His advice includes tax-efficient transfers of such business interests to the succeeding generation and planning for related considerations such as family dynamics, estate liquidity, sufficient cash catamenia, family business concern management structures, buy-sell agreements, and the mitigation of valuation risk through formula gift planning.

LEADERSHIP

Mr. Tsu is a Beau of the American College of Trust and Estate Counsel ("ACTEC") and is a Certified Specialist in both (ane) Manor Planning, Trust & Probate Law and (2) Taxation Law, each by the State Bar of California, Board of Legal Specialization. He has too been selected by his peers for inclusion in The Best Lawyers in America® in the area of Trusts and Estates since 2016 and Tax Law since 2021.

Mr. Tsu serves as Vice Chair of the Estate and Souvenir Taxes Committee of the American Bar Association Section of Taxation and on the Taxation Executive Committee of California Lawyers Clan. He is a member of the YMCA of San Diego Canton Gift Planning Advisors' Council, the Executive Lath of the Society of Trust and Estate Practitioners ("STEP") San Diego, and of the San Diego chapters of the Boston College and Academy of Dayton Alumni Associations.

Mr. Tsu is a regular speaker and contributing member of the American Bar Association, Tax and Real Property, Trust & Estate Sections; STEP; the State Bar of California, Revenue enhancement and Trusts & Estate Sections; the California Lodge of CPAs; and the San Diego County Bar Association, Manor Planning, Trust & Probate Section.

Speaking & Teaching Engagements

  • Charitable Pb Annuity Trusts, Rancho Santa Iron Foundation – Vino, Wealth and Wisdom, July 27, 2020 (Presenter)
  • Qualified Severances – New GSTT Solutions in an Old Wineskin, American Bar Clan – Section of Taxation's Virtual 2020 May Tax Meeting, July 9, 2020 (Presenter)
  • Tax Planning Matters, Revenue enhancement Procedure and Tax Returns I, Continue Educational activity and the Bar – Estate Planning Intensive Grade ("EPIC"), June 24, 2019 (Presenter)
  • S. Income Revenue enhancement of Foreign Trusts, California Lawyers Association – Revenue enhancement and Trusts & Estates Sections, February 26, 2019 (Co-Presenter)
  • Strange Trusts, the CFC Rules and the New GILTI Tax, Order of Trust and Estate Practitioners – San Diego, February 19, 2019 (Co-Presenter)
  • Dual National Beneficiaries of Foreign Trusts: UNI, PFICs and GILTI Revenue enhancement – Treasury
  • Regulations Run Amok, University of San Diego School of Police force Procopio International Taxation Plant, November 2, 2018 (Co-Presenter)
  • California in the Lurch – Impact of TCJA on Individuals, Trusts & Estates, California Lawyers Association, Annual Meeting, September 15, 2018 (Presenter)
  • Things Every Domestic Estate Planner Should Know About International Law , Texas Bar CLE, Advanced Estate Planning & Probate, June 15, 2018 (Presenter)
  • Current Developments in Federal Transfer Taxes, American Bar Association, Tax Section – Manor & Gift Taxes Committee, May Meeting, May 11, 2018 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Virtually International Law, American Bar Association, Taxation Section – Estate & Gift Taxes Committee, Midyear Meeting, February 9, 2018 (Co-Presenter)
  • Electric current Developments in Federal Transfer Taxes, American Bar Clan, Tax Section – Estate & Gift Taxes Committee, Midyear Meeting, February 9, 2018 (Co-Presenter)
  • Estate and Souvenir Taxation of Nonresident Aliens, ALI-CLE, International Trust and Manor Planning, November x, 2017 (Presenter)
  • Foreign Trusts: Beware of Tax and Divorce Consequences, State Bar of California Tax Section, Annual Meeting, November 3, 2017 (Co-Presenter)
  • Select Estate Assistants Topics for Foreign Decedents and Strange Beneficiaries, Probate Attorneys of San Diego, May 17, 2017 (Presenter)
  • Current Developments in Federal Transfer Taxes, American Bar Association, Tax Section – Estate & Gift Taxes Committee, May Meeting, May 12, 2017 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Well-nigh International Estate Planning, Dallas Estate Planning Council, March two, 2017 (Co-Presenter)
  • Current Developments in Federal Transfer Taxes, American Bar Association, Tax Section – Estate & Gift Taxes Commission, Midyear Coming together, January xx, 2017 (Co-Presenter)
  • Planning for Foreign Investment in Real Property and FIRPTA for Trustees, American Bar Association, Real Belongings, Trust and Manor Section, May 12, 2016 (Co-Presenter)
  • Wealth Transfer Tax Planning for Nonresidents, Society of Trust and Estate Practitioners – Los Angeles, International Tax and Estate Planning Forum (Pre-Conference), May 4, 2016 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Most International Estate Planning, Northward County Estate Planning Council, Feb 2, 2016 (Co-Presenter)
  • Unanswered Questions in the Fiduciary Tax World, California CPA Society, Advanced Estate Planning Constitute, January 28, 2016 (Co-Presenter)
  • Wealth Transfer Taxation for the International Client, Country Bar of California Tax Department – Young Tax Lawyers San Diego Affiliate, November 18, 2015 (Co-Presenter)
  • Unanswered Questions in the Fiduciary Taxation World, State Bar of California Tax Department, Annual Meeting, November half dozen, 2015 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know About International Estate Planning, ALI-CLE, Manor Planning in Depth, June 23, 2015 (Presenter)
  • Overview of Wealth Transfer Taxation, ALI-CLE, Estate Planning in Depth, June 21, 2015 (Co-Presenter)
  • Wealth Transfer Tax Planning for Nonresidents, Society of Trust and Estate Practitioners – The states, Inaugural STEP The states Conference, June 5, 2015 (Co-Presenter)
  • Section 6166 Planning Problems, American Bar Association, Tax Section, January 30, 2015 (Co-Presenter)
  • Things Every Domestic Manor Planner Should Know About International Estate Planning, ALI-CLE, Estate Planning in Depth, June 24, 2014 (Presenter)
  • Current Developments in Federal Transfer Taxes, American Bar Association, Tax Section – Estate & Gift Taxes Committee, May Coming together, May eleven, 2018 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Almost International Law, American Bar Clan, Taxation Department – Estate & Gift Taxes Committee, Midyear Meeting, February 9, 2018 (Co-Presenter)
  • Current Developments in Federal Transfer Taxes, American Bar Clan, Tax Section – Manor & Gift Taxes Committee, Midyear Coming together, Feb 9, 2018 (Co-Presenter)
  • Estate and Gift Revenue enhancement of Nonresident Aliens, ALI-CLE, International Trust and Manor Planning, Nov 10, 2017 (Presenter)
  • Foreign Trusts: Beware of Taxation and Divorce Consequences, State Bar of California Tax Department, Annual Meeting, November 3, 2017 (Co-Presenter)
  • Select Estate Administration Topics for Foreign Decedents and Foreign Beneficiaries, Probate Attorneys of San Diego, May 17, 2017 (Presenter)
  • Current Developments in Federal Transfer Taxes, American Bar Clan, Tax Section – Estate & Gift Taxes Commission, May Meeting, May 12, 2017 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Well-nigh International Manor Planning, Dallas Manor Planning Quango, March two, 2017 (Co-Presenter)
  • Electric current Developments in Federal Transfer Taxes, American Bar Association, Revenue enhancement Section – Estate & Gift Taxes Committee, Midyear Meeting, January twenty, 2017 (Co-Presenter)
  • Planning for Foreign Investment in Existent Property and FIRPTA for Trustees, American Bar Association, Real Property, Trust and Estate Section, May 12, 2016 (Co-Presenter)
  • Wealth Transfer Tax Planning for Nonresidents, Lodge of Trust and Manor Practitioners – Los Angeles, International Tax and Estate Planning Forum (Pre-Conference), May 4, 2016 (Co-Presenter)
  • Things Every Domestic Manor Planner Should Know About International Estate Planning, Northward County Estate Planning Council, February two, 2016 (Co-Presenter)
  • Unanswered Questions in the Fiduciary Taxation World, California CPA Society, Advanced Manor Planning Institute, January 28, 2016 (Co-Presenter)
  • Wealth Transfer Tax for the International Client, State Bar of California Tax Section – Immature Tax Lawyers San Diego Chapter, November eighteen, 2015 (Co-Presenter)
  • Unanswered Questions in the Fiduciary Revenue enhancement World, State Bar of California Tax Section, Annual Meeting, November 6, 2015 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Well-nigh International Manor Planning, ALI-CLE, Estate Planning in Depth, June 23, 2015 (Presenter)
  • Overview of Wealth Transfer Taxation, ALI-CLE, Manor Planning in Depth, June 21, 2015 (Co-Presenter)
  • Wealth Transfer Revenue enhancement Planning for Nonresidents, Society of Trust and Manor Practitioners – Us, Inaugural STEP USA Conference, June 5, 2015 (Co-Presenter)
  • Department 6166 Planning Issues, American Bar Clan, Tax Section, January xxx, 2015 (Co-Presenter)
  • Things Every Domestic Estate Planner Should Know Near International Estate Planning, ALI-CLE, Estate Planning in Depth, June 24, 2014 (Presenter)

Awards & Honors

  • Recognized past Best Lawyers in America© (Trusts and Estates, 2016-2022) (Taxation Police, 2021-2022)

Best Lawyers Award Badge

Affiliations

  • American College of Trust and Estate Counsel, Fellow
  • State Bar of California, Revenue enhancement Section, Executive Committee Member (2018-present)
  • State Bar of California, Trusts & Manor Department
  • San Diego County Bar Association, Estate Planning, Trust & Probate Section
  • American Bar Association, Section of Taxation, Estate & Gift Taxes Committee - Vice Chair (2018-present)
  • American Bar Association, Department of Real Holding, Trust & Estate Law
  • STEP San Diego, Executive Board (2017-present)
  • California Lodge of CPAs
  • YMCA of San Diego County Gift Planning Advisors' Quango (Trusts and Estates, 2016-2021) (Tax Law, 2021)
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