Individual International Tax Issues - Comprehensive Coverage

Learning Objectives

• To identify the issues and logistical complications from foreign financial institutions seeking to meet complex U.S. institutional standards
• To recognize the FBAR Penalties and their enforcement
• To recognize differences in tax scope between nonresident aliens and United States taxpayers
• To recall the practical guide to planning tools and techniques for clients who are nonresident aliens contemplating residency/citizenship changes
• To identify the Techniques for ownership of U.S. situated assets by non-U.S. taxpayers.

Course Description

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

MAJOR TOPICS COVERED:

• FinCEN Report
• What happened to the prior programs after the increased emphasis of FBAR. 
• FBAR Penalties
• FBAR Penalty Enforcement
• About Form 8938
• Additional Reporting Forms

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.

MAJOR TOPICS COVERED:

• Income and branch profits tax
  
• FIRPTA
• FDAP Income
• Tax Treaties
• Foreign Trusts

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.