Dina Kapur Sanna

Kapur Sanna
Day Pitney LLP

Dina Kapur Sanna, partner in the Individual Clients Department, practices in the area of U.S. federal tax planning for high net worth individuals with property interests and/or heirs in more than one country.

Dina has considerable experience in the development of wealth management structures for residents and nonresidents of the United States. Such structures accommodate multijurisdictional tax and legal considerations in order to maximize tax efficiency from a global perspective, particularly where future generations are, or may become, residents or domiciliaries of the United States. She has had significant exposure to U.S. federal income and transfer tax issues affecting U.S. residents with non-U.S. assets and income and nonresidents with U.S. assets and income, including income and transfer tax treaty analysis and interpretation; rules applicable to income taxation of complex non-U.S. trusts and their beneficiaries; the antideferral regimes relevant to direct and indirect U.S. shareholders of certain non-U.S. corporations; and preimmigration and expatriation tax planning.

Dina is a frequent speaker at international tax and estate planning seminars around the world, including New York, Miami, Los Angeles, London, Switzerland, and Bermuda. She also has written or co-written several articles on international estate planning topics that appeared in periodicals such as The New York Law Journal, Trusts & Estates magazine, the STEP USA Journal; and Estate Planning magazine.

Dina received her B.A. in Economics, magna cum laude, from Lehigh University in 1993, where she was a member of Omicron Delta Epsilon, the International Economic Honorary Society. She received her J.D., with Honors, from the George Washington University National Law Center in 1996, where she also graduated Order of the Coif. Dina also holds a Master of Law (LL.M.) degree in taxation from New York University School of Law, which she received in January 2000.

Dina was recognized as a leading wealth management attorney by Chambers USA Legal Directory and has been consistently included in Best Lawyers in America since 2007. She is a fellow of the American College of Trusts and Estate Counsel (ACTEC).

IRS Issues Final Regs for Reporting of Foreign Financial Assets
On Feb. 22, the IRS issued final regulations to further implement IRC Section 6038D, which imposes on certain U.S. taxpayers a requirement to report “specified foreign financial assets” if the aggregate value of such assets exceeds applicable thresholds.
IRS Issues Proposed Regs Taxing Gifts and Bequests From Covered Expatriates
On Sept. 9, the IRS published proposed regulations to implement IRC Section 2801, which imposes a tax on U.S. citizens and residents who receive gifts or bequests from individuals who relinquished U.S. citizenship or ceased to be lawful permanent residents of the United States on or after June 17, 2008.
A Critical Time for Voluntary Disclosure of Foreign Assets 
Dina Kapur Sanna & Sam C. Shulman discuss the recent changes to foreign asset disclosure protocols
FATCA and Non-U.S. Trusts: An Overview 
Rachel J. Harris & Dina Kapur Sanna highlight how the final regulations apply to foreign structures
The HIRE Act 
The Hiring Incentives to Restore Employment Act (the HIRE Act)1 of 2010, found in Internal Revenue Code Section 6038D, enacted foreign asset disclosure
Calling for Clarity On NRAs' Partnership Situs 
There are various theories proposed for determining situs of partnership interests for U.S. federal estate tax purposes when those interests are held
When U.S. Clients Receive Money From Foreign Family Members 
Many clients think the foreign trust tax and reporting rules can be circumvented by using non-U.S. persons as nominees. But the United States has rules
Nonresident Aliens 
The gross estate of a nonresident alien1 (NRA) is determined in the same manner as the gross estate of a U.S. resident or citizen, although it's generally
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