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Navigating International Domicile Changes: Residency Issues, Exit Tax, and Green Card Revocations

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, July 11, 2023

Recorded event now available

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This webinar will highlight the factors to consider when making an international domicile or residency change. The panelist will cover key considerations taxpayers should make before moving into or out of the U.S.

Description

The last few years have seen a marked increase in domicile/residency changes by high-net-worth individuals--particularly at the international level. Additionally, there is marked increase in the U.S. citizens and green card holders seeking to renounce their citizenship or US green card. An international domicile or residency change can be undertaken by an individual for many reasons - retirement, political reasons, return to the home country, or employment-related. Whatever be the reason, a thorough understanding of the effect of a move/change on an individual’s global tax position should be thoroughly reviewed.

Listen as Ragini Subramanian, Senior Manager, International, Private Client Services at Eisner Advisory Group, explains essential factors for taxpayers and advisers to consider for international residency changes while taking into account country examples where possible. The presenter will also provide a comprehensive review of Impact of green card/ US citizenship revocations.

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Outline

  1. Country specific residency rules
  2. Worldwide versus territorial system of taxation across various jurisdictions
  3. Country tax rates and impact on overall tax position
  4. Special rules associated with real property holdings
  5. Holding structure for various investments
  6. Foreign tax credit planning
  7. Residency starting and ending dates in the new jurisdictions and in the US
  8. Estate and gift tax impact of domicile change
  9. Pre-domicile change planning examples
  10. Exit tax under section 877A

Benefits

The panelist will review these and other critical issues:

  • What may be a US tax impact of a given holding structure for foreign investments
  • How the treaty tie-breaker rules are used to determine domicile
  • Critical length of stay considerations for residency
  • What are the necessary steps to revoke green card status?

Faculty

Subramanian, Ragini
Ragini Subramanian
Senior Manager, International, Private Client Services
Eisner Advisory Group

Ms. Subramanian is a Tax Senior Manager in the Private Client Services Group. With over 10 years of tax experience, she...  |  Read More

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