Ashley A. Weyenberg
Ashley focuses her practice on high-net worth, business-connected individuals and families. She advises domestic and international business owners, executives and family groups on a wide range of matters including: estate planning and administration, trust structuring and administration, business succession and governance, pre-residency and pre-expatriation planning, structuring and operation of family offices and private trust companies, charitable planning, and assistance with matters involving the IRS, including obtaining advance private rulings and audit disputes.
Prior to joining Thompson Hine, Ashley was a Senior Manager in the Private Client Services group of Ernst & Young LLP’s National Tax Department in Washington, D.C., where she spent nearly six years advising U.S. and international clients on a wide range of income, gift, and estate tax matters.
Tax and Business Planning
- Collaborated on the design of many GST exempt trusts, including creating many tailored economic and tax models for installment sales to grantor trusts and sales in exchange for self-cancelling installment notes.
- Assisted in the design and implementation of many trust decanting transactions to accomplish client goals such as to add flexibility to existing but outdated trust structures and minimize state-level tax burdens.
- Designed many annual gift trusts and education trusts for grandchildren as an alternative to less flexible saving-type accounts for minors.
- Designed many irrevocable life insurance trusts and funding transactions, including structuring many life insurance sales that maintain favorable tax treatment for policy proceeds.
- Prepared and reviewed many U.S. federal and state gift and estate tax returns and represented taxpayers in IRS gift and estate audits.
- Prepared comprehensive estate plans for high-net worth, business-connected clients and their family members, including the CEO of a publicly-traded company, many closely-held business owners, and philanthropists.
- Designed and implemented strategies to assist clients with existing trust structures, including renegotiating sale strategies and cash flow management.
International Private Client Planning
- Prepared comprehensive estate plans for individuals and couples that have citizenship or residency in multiple jurisdictions and/or assets in multiple jurisdictions.
- Represented the executors of many foreign estates with dual-citizen/resident decedents or global assets, including preparation of non-U.S. citizen/resident estate tax returns, which often include various favorable treaty-based return positions (including recently United Kingdom, Japan, France, Switzerland, Channel Islands, Canada, and Spain).
- Designed numerous structures for high net worth foreign individuals and family groups to hold U.S. situs assets.
- Designed many structures for foreign individuals and family groups to hold personal-use and rental real estate in the U.S.
- On multiple occasions advised the trustees of U.S. trusts regarding the owners of non-U.S. assets and the implications and considerations for making distributions to beneficiaries who previously expatriated from the U.S.
- Assisted many non-U.S. clients with IRS controversies, including gift tax examinations, reasonable cause and voluntary disclosures.
- Opined on the U.S. tax classification of many offshore entities, pensions and other arrangements, such as Liechtenstein anstalts and stiftungs, German usufructs, holding companies and land trusts, and Australian superannuation funds and unit trusts.
- Assisted numerous clients with foreign informational return matters, including foreign bank account reports (FBAR), foreign financial assets, foreign mutual funds and receipt of foreign gifts and inheritances.
- Analyzed and managed complexities of U.S. and foreign trusts and estates, including implications to beneficiaries on distribution and inheritance.
- Designed multiple charitable lead trusts and charitable remainder trusts.
- Assisted in the establishment of a community-owned national public radio member station and in obtaining tax-exempt status, being the first transaction of its kind in the U.S.
- Contributor to authors, International Quarterly, Leimberg Estate Planning Newsletter, 2016-2017
- Contributor, “Recent Developments in Estate Planning,” The Tax Advisor (AICPA), 2013-2017
- Contributor, The Tax Guide, Ernst & Young, 2011-2017
- Editor and contributor, International Estate and Inheritance Tax Guide, Ernst & Young, 2011-2016
- Co-author, “IRS relaxes ‘bona fide residency’ test for individuals living in U.S. territories,” ABA Section of Real Property, Trust and Estate Law eReport, 2015
- Editor, “Section 1411: A brief history, overview and its application outside of Chapter 2A,” BNA Portfolio, 2015
- Co-author, “Chapter 22 United States Tax: International Compliance Considerations for the Individual Client,” A Guide to International Estate Planning, ABA Book Publishing, 2014
- “Highlights and pitfalls for non-U.S. citizen surviving spouses—The estate tax marital deduction and the dilemmas of portability,” ABA eReport, 2013
- Co-author, “Foreign Trusts: Form 3520 and Form 3520-A,” Probate & Property Magazine, 2013. The article was the editor’s selection for the “Best Overall Trust & Estates Article” 2013 Excellence in Writing Award.
- Co-author, “Offshore voluntary disclosure initiative and FBAR efiling requirements as FinCEN goes paperless,” ABA eReport, 2012
- “GST-Non Exempt Trust…Are you Sure?”, 16th Annual Estate Planning Seminar, Cleveland, Ohio (September, 2021)
- Co-presenter, “A primer: U.S. taxpayers moving to and living in the U.S. territories,” The Society of Trust and Estate Practitioners (STEP) Mid-Atlantic Branch (2015)
- Series 65 – Registered Investment Advisor Representative, District of Columbia (Inactive)
- Ohio State Bar Association
- District of Columbia Bar Association
- American Bar Association – Real Property, Trusts & Estate Section
- Omega Community Development Corporation (The Hope Center), 2020 to present
- SICSA Pet Adoption & Wellness Center, 2021 to present
- Dayton Performing Arts Alliance, Planned Giving Committee, 2017 to present
- Wills for Heroes, 2017
- Martha’s Table, Washington, D.C., 2014
- Academy of Hope, Washington, D.C., 2012-2013
Thompson Hine Elects 11 New Partners Thompson Hine LLP
January 26, 2021