Expatriation Tax Planning for U.S. Citizens and Long-Term Permanent Residents
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a comprehensive look at critical planning issues and tasks for U.S. citizens planning to expatriate, including U.S. taxpayers planning to renounce their citizenship, and green card holders and other foreign citizens with long-standing U.S. tax presence and/or filing requirements. The webinar will address the "exit tax," detail steps to minimize the tax impact of expatriating, and outline the filing requirements both before and after expatriation.
Outline
- Who is a covered expatriate?
- The three tests
- The exceptions
- Determining net worth when trust assets are involved
- Applicable taxes under Section 877A
- The inheritance tax under Section 2801
- Planning techniques
Benefits
The panel will review these and other compelling issues:
- Who is impacted by Section 877A?
- How to calculate the mark-to-market tax on capital gains?
- What types of deferred compensation are subject to the exit tax?
- The effect of the expatriation rules on U.S. gift and estate taxes
- Strategies for avoiding or minimizing the taxes imposed under Section 877A
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Kerrin N.T. Liu
Partner
Diosdi & Liu
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations,... | Read More
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court. Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.
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Cannot Attend January 23?
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.