Course Description
Some of your
clients are US citizens who may be thinking of giving up their citizenship.
This number may be small, but many of your clients are green card holders.
How many green
card holders truly understand what will happen to them if they hold the card for
8 “tax years” (that can be far less than 8 calendar years!) and then relinquish
the card?
How many
understand that merely because the card has “expired” for immigration purposes,
the mere expiration does not let them off the hook for tax purposes?
Green card
holders with expired cards remain liable for paying US tax as tax residents. In
addition, those “expired” years count in determining if they have held the card
long enough to be subject to the “expatriation” tax regime once the card is
formally relinquished or administrative action is taken.
If the US
citizen giving up citizenship, or the green card holder giving up the card is
classified as a “covered expatriate” (CE), the expatriation regime applies. The
regime will impose an “exit tax” on a deemed sale of the client’s worldwide
assets. Additionally, a 40% transfer tax will be imposed on any US recipients
of a gift or inheritance from the CE at any time in the future.
Understanding how to advise clients about the complex
tax aspects of the US “expatriation” tax regimes can create a whole new line of
business for tax advisors, enrolled agents, and return preparers seeking to
expand their US tax practice.
Don’t lose
potential big business opportunities because you do not fully understand the
expatriation rules. The regimes should be understood by any client who is
thinking of obtaining a green card or US citizenship, as well as by those
thinking of relinquishing the card or citizenship.
Expatriation
matters have grown in importance over the years as more and more individuals
are divorcing from the United States. The IRS now has an audit campaign in
place for individuals expatriating any time after June 2008. It is aggressively
seeking unpaid exit tax and penalties.
Now more than ever, tax professionals need to understand the
expatriation rules and how to engage in constructive tax planning for clients
to escape the harsh results. This CPE course provides all the information you
need.
This CE/CPE Tax course will provide an in-depth
examination of the overall framework and rules surrounding the expatriation tax
rules. This is one of the most complex and misunderstood areas in US
international tax. The rules have changed several times over the years, adding
to the complexity. My CPE course makes it easy and digestible.
