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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.

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.

About Presenter

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.

FAQ

  • To receive CPE credit for the event, you must register for the webcast prior to the start of each program.
  • CPE is available to all eligible participants within 24 hours of each webinar.
  • You must attend complete webinar and respond to all polling questions asked during the webinar. CPE is issued on 50 minute credit hour basis.
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  • This event may be a recorded rebroadcast of a live event done in past and the instructor will be available to answer your questions during/after the webinar.
  • If you are Canadian Chartered Professional Accountant (CPA) many of our courses qualifies for your verifiable CPD requirements you will get your certificate for the program. You can check a tab of “Webinar Qualifies for” for the same.However please do verify with respective regulatory body about the eligibility for the same.
  • Many of our courses are approved by “CFP Board” for CE credits of certified financial Planner(CFP). Please check a tab of “Webinar Qualifies for” to verify whether webinar qualifies for CE credits for CFP or not.

Refund/Cancellation Policy

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).

Reviews

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  • LM
    LILLIAN MCKAY , CPA
    Sep 4th 2020
    Always a good presentation! Appreciate periodic inputs, especially with displaced domestic and foreign workers, immigration limbo and covid issues!- every relevant info matters! By providing detailed and thorough coverage, Patrick has again shared his expertise which is extremely valuable as reference
NT
Nancy Thompson , CPA
It was great to have the handout to look at later. Material was relevant, I just filed two Spanish residents (U.S. Citizen) and had to go lots of research and double checking myself. Also put a call into the IRS center in TX, they were very helpful.
LM
LILLIAN MCKAY , CPA
The webinar Patrick McCormick gave was one of the most informative webinars I've ever taken. He covered a great deal of content while being both concise and clear. Great webinar, As always Patrick does an excellent job of explaining complex technical areas of foreign tax issues in an understandable fashion

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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.

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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

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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.

upcoming Live CPE Webinars

S-Corp Preparation, Basis Calculations & Distributions – Form 1120S Schedule K & K-1 Analysis
Wednesday, November 25, 2020 | 10:00 AM EST View Details/Register
Annual Federal Tax Update - C & S Corporations, Partnerships & LLCs (Forms 1120, 1120S & 1065)
Wednesday, November 25, 2020 | 10:00 AM EST View Details/Register
How to deal effectively with IRS Examinations and Criminal Investigations?
Wednesday, November 25, 2020 | 10:00 AM EST View Details/Register
Winning the Fraud Battle in the 21st Century: Prevention and Detection
Wednesday, November 25, 2020 | 10:30 AM EST View Details/Register
Tactical and Strategic Roth Conversions in 2020 after the Secure Act (Latest Update)
Wednesday, November 25, 2020 | 10:30 AM EST View Details/Register
QBO: Banking Feed and Reconciling - Make Rules & Automate
Wednesday, November 25, 2020 | 11:00 AM EST View Details/Register
Best Workshop on Partnership & LLC (Form 1065) Tax Return Review & Case Study (NEW)
Wednesday, November 25, 2020 | 08:00 AM PST View Details/Register
How to not be an HR Failure – from an employment law perspective
Wednesday, November 25, 2020 | 11:00 AM EST View Details/Register
Detailed Workshop on IRS Audit, Representation, Resolution.
Wednesday, November 25, 2020 | 08:00 AM PST View Details/Register
Practical Guide To Fraud 2020: Including Cash, Inventory & General Frauds
Wednesday, November 25, 2020 | 08:00 AM PST View Details/Register
Crucial Insights for Real Estate: Part 3
Wednesday, November 25, 2020 | 11:00 AM EST View Details/Register
Fundamentals of Income Taxation of Trusts & Form 1041 Planning: What Every Advisors Needs to Know
Wednesday, November 25, 2020 | 12:00 PM EST View Details/Register
The Structure and Organization of the IRS
Wednesday, November 25, 2020 | 12:30 PM EST View Details/Register
Business Tax Update 2020
Wednesday, November 25, 2020 | 01:00 PM EST View Details/Register
Crucial Insights for Real Estate: Part 4
Wednesday, November 25, 2020 | 01:30 PM EST View Details/Register
  • Cost $80
  • CPE Credits 8
  • CE Credits 8
  • IRS Course ID GEHNZ-T-00273-20-O
  • CTEC Course ID 6273-CE-0279
  • Subject Area Taxes
  • Course Level Basic
  • Instructional Method group internet based
  • Prerequisites None
  • Advanced Preparation None
  • Who should attend? Enrolled Agent Tax Attorney Tax Practitioners CFO/Controller Non Profit Pros CPA - Small Firm CPA - Mid Size Firm CPA - Large Firm Accounting Firm Tax Pros Auditors Tax Firm Young CPA CPA in Business Entrepreneurial CPA Tax Accountant (Industry) Tax Director (Industry) Cloud Firms Tax Managers Tax Preparer Staff of Accounting Firm
  • Handout Material Download

upcoming Live CPE Webinars

S-Corp Preparation, Basis Calculations & Distributions – Form 1120S Schedule K & K-1 Analysis
Wednesday, November 25, 2020 | 10:00 AM EST View Details/Register
Annual Federal Tax Update - C & S Corporations, Partnerships & LLCs (Forms 1120, 1120S & 1065)
Wednesday, November 25, 2020 | 10:00 AM EST View Details/Register
How to deal effectively with IRS Examinations and Criminal Investigations?
Wednesday, November 25, 2020 | 10:00 AM EST View Details/Register
Winning the Fraud Battle in the 21st Century: Prevention and Detection
Wednesday, November 25, 2020 | 10:30 AM EST View Details/Register
Tactical and Strategic Roth Conversions in 2020 after the Secure Act (Latest Update)
Wednesday, November 25, 2020 | 10:30 AM EST View Details/Register
QBO: Banking Feed and Reconciling - Make Rules & Automate
Wednesday, November 25, 2020 | 11:00 AM EST View Details/Register
Best Workshop on Partnership & LLC (Form 1065) Tax Return Review & Case Study (NEW)
Wednesday, November 25, 2020 | 08:00 AM PST View Details/Register
How to not be an HR Failure – from an employment law perspective
Wednesday, November 25, 2020 | 11:00 AM EST View Details/Register
Detailed Workshop on IRS Audit, Representation, Resolution.
Wednesday, November 25, 2020 | 08:00 AM PST View Details/Register
Practical Guide To Fraud 2020: Including Cash, Inventory & General Frauds
Wednesday, November 25, 2020 | 08:00 AM PST View Details/Register
Crucial Insights for Real Estate: Part 3
Wednesday, November 25, 2020 | 11:00 AM EST View Details/Register
Fundamentals of Income Taxation of Trusts & Form 1041 Planning: What Every Advisors Needs to Know
Wednesday, November 25, 2020 | 12:00 PM EST View Details/Register
The Structure and Organization of the IRS
Wednesday, November 25, 2020 | 12:30 PM EST View Details/Register
Business Tax Update 2020
Wednesday, November 25, 2020 | 01:00 PM EST View Details/Register
Crucial Insights for Real Estate: Part 4
Wednesday, November 25, 2020 | 01:30 PM EST View Details/Register