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There are many issues related to International Tax Reporting which are ignored by companies. For tax practitioners, this has made a working knowledge of the United States tax laws related to international ties an absolute necessity. In this 8-hour webinar Tax Attorney Mr. Patrick Mccormick will discuss FBAR Penalties, Form 8938, differences in tax scope between nonresident aliens and the United States taxpayers, both for income tax and estate/gift tax purposes, FDAP Income, FIRPTA, International Tax for multinational performers, entertainers, professionals and Implications from income tax.
Session-1 - FOREIGN ACCOUNTS TEN YEARS AFTER THE UBS SCANDAL
The United States reporting landscape for foreign accounts has dramatically changed since the Swiss bank account scandal of the late 2000s. Given heightened enforcement of reporting requirements, standards for FBAR penalties have been well-developed – both by case law and internal Service guidance. Holding foreign accounts has become more complex – based both on U.S. information reporting issues and logistical complications from foreign financial institutions seeking to meet complex U.S. institutional standards
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Session-2 - PRE-IMMIGRATION TAX PLANNING STRATEGIES
This webinar will provide tax advisers with a practical guide to planning tools and techniques for clients who are nonresident aliens contemplating residency/citizenship changes which will render them United States, taxpayers. The seminar will discuss differences in tax scope between nonresident aliens and United States taxpayers, both for income tax and estate/gift tax purposes. The seminar will then detail strategies for minimizing income and transfer tax post-residency, including basis strategies for non-U.S. situs assets, structuring “drop-off” trusts, and planning for the possibility of the nonresident alien’s return to the country of origin.
Session-3 - STRUCTURING UNITED STATES INVESTMENTS BY FOREIGN TAXPAYERS
The United States imposes a multitude of tax requirements on United States taxpayers with foreign investments, whether through information reporting requirements or, in the case of foreign corporations, immediate inclusions for what otherwise would be deferred income.
Rather curiously by juxtaposition, foreign taxpayers making investments in the United States often find favorable tax provisions, including exemptions from tax for many capital gains items. It is critical, however, to properly structure United States investments by foreign taxpayers, looking both at relevant considerations and common techniques.
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Session-4 - INTERNATIONAL TAX FOR ATHLETES, SPORTS PROFESSIONALS ENTERTAINERS, ARTIST, AND THEIR ADVISERS & CREW MEMBER
For multinational performers, entertainers, professionals, United States tax issues add a complex variable to American activities. Passive acquisition of United States supporters will not by itself create United States tax consequences for a multinational professional. By default, nonresidents performing services and earning income therefrom in the United States are subject to American tax; foreign jurisdictions usually impose similar rules.
However, this professional with substantial American connections are subject to onerous tax rules for nonresidents; relief options are available both to nonresidents generally and artists and entertainers specifically. This program addresses United States tax considerations for performers, primarily focused on nonresident performers (as, for United States-based taxpayers, American tax consequences are comparatively straightforward). This program covers both general rules applicable to service performers and special options – including treaty and withholding relief – specific to entertainers.
Session -5 - INTERNATIONAL TAX: CONCEPTS IN A GLOBAL SOCIETY
As the world becomes more global, an exponentially increasing number of individuals have some sort of international ties – whether through family, assets, employment, or a multitude of other factors. For tax practitioners, this has made a working knowledge of the United States tax laws related to international ties an absolute necessity. The webinar introduces basic concepts associated with international tax as it relates to individuals – including classification of taxpayers, implications from an income tax and transfer tax perspective, required information forms, and options for curing prior failures to properly report. It will provide functional knowledge of international tax to speak knowledgeably with clients on international issues & advise appropriately of considerations.
Join this CPE webinar to understand the differences in tax scope between nonresident aliens and the United States taxpayers, both for income tax and estate/gift tax purposes, FDAP Income, FIRPTA, International Tax for multinational performers, entertainers, professionals, and Implications from income tax and the structuring of United States investments by foreign taxpayers and help your clients. This webinar is recommended for but not limited to CPAs, EAs, Tax Practitioners, Tax Professionals.
Patrick is a partner with Culhane Meadows, a national law firm with a prominent practice in the international area. Patrick practices exclusively in the area of international taxation. He has extensive experience in handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with international tax issues faced by their clients.
Patrick is a prolific contributor to a multitude of international tax journals, including Tax Notes and the Journal Of International Taxation, . He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPA Academy on assorted international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and a LL.M. from New York University School of Law. His bar admissions include Pennsylvania, Florida, New Jersey and Georgia.
Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication, named Patrick Estate Planning Lawyer of the Year (United States) for both 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.
Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.
For more information regarding refund, complaint and program cancellation policies, please contact our offices at 646-688-5128
In case any of the course or live webinars gets cancelled we would be refunding you the entire amount (if paid).
MY-CPE LLC (Sponsor Id#: 143597) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.NASBARegistry.org.
MY-CPE LLC (Sponsor Id#: GEHNZ) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary
MY-CPE LLC (Sponsor ID# : 6273) has been approved by the California Tax Education Council to offer continuing education courses that count as credit towards the annual “continuing education” requirement imposed by the State of California for CTEC Registered Tax Preparers. A listing of additional requirements to register as a tax preparer may be obtained by contacting CTEC at P.O. Box 2890, Sacramento, CA, 95812-2890, toll-free by phone at (877) 850-2832, or on the Internet at www.ctec.org.