U.S. Tax Planning for Foreign Nationals: Sourcing of Income, Exemptions, Tax Treaties, and Pitfalls to Avoid
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax professionals guidance on key U.S. tax planning strategies available to foreign nationals and pitfalls to avoid. The panel will discuss key considerations for resident and nonresident aliens for U.S. tax purposes, sourcing of income and challenges that disrupt tax planning, available exemptions and the use of tax treaties, and U.S. tax planning tips for foreign nationals.
Outline
- Rules and regulations regarding foreign nationals and U.S. income tax system
- Determining taxpayer status, filing, and reporting requirements
- Income sourcing and classification
- Tax treaties and reducing or eliminating U.S. tax on income
- Best practices for compliance and tax planning techniques for foreign nationals
Benefits
The panel will review these and other high priority issues:
- U.S. tax rules and regulations applicable to foreign nationals
- Determining resident and nonresident alien status
- Differences in U.S. tax systems and reporting for resident versus nonresident aliens
- The effect of tax treaties the U.S. has with other countries
- U.S. tax planning techniques for foreign nationals and pitfalls to avoid
Faculty
Michael Dana
Partner
Husch Blackwell
Mr. Dana provides tax and corporate law advice to businesses at all phases of operation, from initial business... | Read More
Mr. Dana provides tax and corporate law advice to businesses at all phases of operation, from initial business formation to disposition and all points in between. He advises clients across virtually all areas of operation regarding U.S. federal income tax issues. Mr. Dana has represented U.S.-based, foreign-based, and multinational enterprises, providing advice in connection with acquisitions, distribution structures, and internal reorganizations, including complex crossborder transactions; U.S. Subpart F income and GILTI planning and analysis; foreign tax credit planning and analysis; tax treaty analysis, and other matters related to outbound and inbound U.S. tax planning. His representations have included business structures, operations, and investments by US clients in, or by non-US clients from, Europe, Canada, Latin America and a number of other jurisdictions outside of the U.S. He also works with closely held businesses and their owners to develop and implement tax strategies that protect and enhance corporate value.
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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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C. Edward (Ed) Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing... | Read More
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.
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