Stephanie E. Heilborn


Fulbright & Jaworski LLP

Stephanie E. Heilborn

New York

T:+1 212 318 3207

F:+1 212 318 3400

Stephanie Heilborn, a partner in the New York office, has counseled some of the world's wealthiest families and largest financial institutions. She has extensive experience in the implementation of complex tax-planning strategies, international estate planning and trust administration, and fiduciary litigation, and she is a member of Fulbright's FATCA Task Force. She also assists in the formation of and provision of corporate and tax advice to private foundations and other tax-exempt organizations. She has written and lectured frequently on estate-planning topics and has been quoted by The New York Times and Forbes. She also has served as an Adjunct Associate Professor of Law at Brooklyn Law School.

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  • Education

    2000 – J.D., Georgetown University Law Center
    1996 – M.Sc., Management, London School of Economics
    1995 – A.B., Psychology, Harvard University

    Stephanie is licensed to practice law in New York, New Jersey, and before the U.S. District Court for the District of New Jersey.

    While in law school, Stephanie was the Student Editor-in-Chief of The Tax Lawyer, the official journal of the American Bar Association Section of Taxation, from 1999 - 2000.

  • Representative experience
    • Estate planning for entrepreneurs in advance of sale of closely-held business, including transfers of interests in business to children
    • Estate planning for multi-national families involving structuring of entities and trusts to hold non-U.S. assets and gifts from non-U.S. citizens
    • Estate planning for young families involving creation of life insurance trusts and structuring of gifts to minor children
    • Estate planning for financial executive involving significant gifts to charity, planning for deferred compensation and structuring of inheritances from non-U.S. citizen family members
    • Estate planning for U.S. citizens living in the U.K., including planning for new U.K. income tax rules applicable to non-domiciliaries and for foreign real property
    • Representation of large international financial institutions in connection with review of trust agreements for U.S. and non-U.S. persons, including advice regarding U.S. income and transfer tax treatment of trusts and beneficiaries
    • Advising beneficiaries of foreign trusts regarding U.S. income and transfer taxation, including advice regarding accumulation distributions
    • Representation of corporate fiduciaries regarding fiduciary duties and investment of trust and estate assets under New York Prudent Investor Rule
    • Representation of corporate fiduciaries in various litigation matters, including will contests and contested accounting proceedings, in New York Surrogate's Court
    • Estate administration involving valuable artwork and formation of charitable foundations
  • Professional activities
    • American College of Trust & Estate Counsel (ACTEC)
    • American Bar Association
      • International Law Section (Vice-Chair, International Private Client Committee, 2011 - 2012)
      • Real Property, Probate & Trust Law Section
    • New York State Bar Association
      • Trusts and Estates Law Section
    • New York City Bar Association
      • Estate & Gift Tax Committee (2007 - 2009)
    • Society of Trust and Estate Practitioners (STEP), Member
  • Professional honors
    • Leading Lawyers - International - North America, Citywealth Magazine (2012, 2013)
    • New York Metro Super Lawyer - Thomson Reuters (2013)
  • Speaking engagements
    • Panel on "FATCA for Trusts and Estates: What Fiduciaries and Beneficiaries Need to Know," Fulbright & Jaworski L.L.P. Webinar, May 23, 2013
    • "GRATs Versus Sales to Intentionally Defective Grantor Trusts," New York State Society of CPAs Estate Planning Conference, May 21, 2013
    • Panel on "Navigating Through Turbulent Estate Tax Waters," AICPA Sophisticated Estate Planning for Your Wealthy Clients Conference, October 22, 2012
    • Co-Presenter, "Estate Planning for Resident and Non-Resident Aliens," Strafford Webinar, September 20, 2012
    • Co-Presenter, "Invest in Yourself: Wealth Management and Investing," Women's Tennis Association, August 24, 2012
    • "Estate Planning for the Rest of 2012:  Making the Most of Current Opportunities," AXA Women's Summit, August 6, 2012
    • Moderator, Panel on "Representing the International High Net-Worth Client: Navigating the New Regulatory Order," ABA International Law Section Spring Meeting, April 18, 2012
    • Panel on "Family Office Nuts and Bolts," New York State Society of CPAs, Second Annual Family Office Conference, February 1, 2012
    • "Buy-Sell Agreements," New York State Society of CPAs Estate Planning Conference, October 25, 2011
    • "Revocable Trusts," New York State Society of CPAs, November 23, 2010
    • "Planning for Post-Death Elections," PLI 41st Annual Estate Planning Institute, September 14, 2010
    • "Charitable Lead Trusts," New York State Society of CPAs, April 22, 2010
    • Panel on "Delaware Difference vs. the World," Delaware Trust Conference, December 2, 2009
    • "Grantor Trusts," Program on Income Taxation of Trusts & Estates, New York City Bar, June 9, 2009
    • "Planning With Retirement Benefits," Program on Estate Planning for Spouses, New York City Bar, April 29, 2008
    • "Foreign Trusts," Program on Income Taxation of Trusts & Estates, New York City Bar, June 22, 2006
    • "Post-Mortem Tax Planning," Pace University Law School Center for Continuing Legal Education, September 14, 2005
    • "Gifts by Fiduciaries," Program on Hot Topics in Trusts and Estates Law," New York County Lawyers' Association, January 24, 2005
    • "Women in Big Law Firms," Harvard Law School, October 20, 2003
  • Publications
    • Co-author with Michelle Schwartz, "Estate Planning for Real Estate Investors in 2014: The Medicare Tax and More," Probate & Property, Vol. 28 No. 1, January/February 2014
    • Co-author with Brian G. Smith, "Drafting Trusts for FATCA after the Final Regulations," Estate Planning, Vol. 40, No. 10, October 2013
    • Co-author, "Between Obamacare and the Bush Tax Cuts, Taxes Will Increase in 2013, But How Much? Can Planning Help?," Fulbright Briefing, August 27, 2012
    • Co-author with Andrius Kontrimas, Robert Morris and Zhusong Yang, "IRS Provides Updated Information For 2012 Offshore Voluntary Disclosure Program," Fulbright Briefing, August 1, 2012
    • Co-author with Joseph Sleeth, Jr., Philip Michaels and Michelle Schwartz, "Tax Alert for Non-U.S. People Owning U.S. Property," Fulbright Briefing, June 26, 2012
    • Co-author with Meryl Finkelstein, Philip Michaels, and Brian Smith, "New York Decanting Statute," Fulbright Briefing, February 9, 2012
    • Co-author with Philip Michaels, Joseph Sleeth, Jr. and Lindsay Brown, "Tax Changes Effective as of January 1, 2012: Significant Implications For Estate Planning," Fulbright Briefing, January 20, 2012
    • "Disclaimers," The ABA Practical Guide to Estate Planning (Jay A. Soled, Ed.), 2011
    • Co-author with Philip Michaels and Jaclyn Feffer, "The New York Marriage Equality Act and Its Impact on Estate and Tax Planning," Fulbright Briefing, September 1, 2011
    • Co-author with Kathryn Keneally and Lindsay H. Brown, "New IRS Holistic Audit Program," Trusts & Estates, Vol. 149 No. 8, July 2010
    • "The Complete Guide to Severances for GST Tax Purposes," Estate Planning, Vol. 36 No. 6, June 2009
    • "Book Review: The Faithless Fiduciary and the Quest for Charitable Accountability, 1200-2005," Real Property, Trust and Estate Law Journal, Vol. 43 No. 4, April 2009
    • Co-author with Jonathan G. Blattmachr, "Planning Options For UTMA Accounts and Other Transfers to Minors," Estate Planning, Vol. 35 No. 1, Part 2 of 2, January 2008
    • Co-author with Jonathan G. Blattmachr, "Planning With UTMA Accounts and Other Transfers to Minors," Estate Planning, Vol. 34 No. 12, Part 1 of 2, December 2007
    • Co-author with Jonathan G. Blattmachr, Mitchell M. Gans and Diana S.C. Zeydel, "Proposed Retained Interest Regs: Much Left Unanswered," Tax Notes, Vol. 116 No. 2, July 9, 2007
    • Co-author with Jonathan G. Blattmachr and Mitchell M. Gans, "Gifts by Fiduciaries by Tax Options and Elections," Probate & Property, Vol. 18 No. 6, November/December 2004
      • Winner of 2004 Probate & Property Award for "Best Cutting-Edge Article"
    • Co-author with Jonathan G. Blattmachr and Mitchell M. Gans, "Some Good News About Grantor Trusts: Rev. Rul. 2004-64," Estate Planning, Vol. 31 No. 10, October 2004
  • Civic involvement
    • MoMA (Museum of Modern Art) Planned Giving Advisory Committee, member
  • Licenses
    • New Jersey State Bar License
    • New York State Bar License
  • Interests

    Stephanie enjoys traveling, photography, opera, hiking, tennis and sailing.