PRE-IMMIGRATION TAX PLANNING STRATEGIES

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PRE-IMMIGRATION TAX PLANNING STRATEGIES

Friday, September 13, 2019

5 (1)

Presenter :Patrick McCormick, DL, LLM

Company :Culhane Meadows

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Course Details

Overview of Topics

Introduction to the subject4 mins
Non-Resident Aliens – Income Tax, ECI, FIRPTA, FDAP Income, Income Tax Treaties, Transfer Taxes7 mins
US Taxpayers – Income Tax, Transfer Tax,31 mins
US Taxpayers vs. Nonresident Aliens – Income Tax, Transfer Tax42 mins
Income Tax Planning Opportunities in the Pre-immigration Context54 mins
Transfer Tax Planning Opportunities in the Pre-immigration Context70 mins

Course Description

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.

Learning objectives

Differences in tax scope between nonresident aliens and United States taxpayers
Practical guide to planning tools and techniques for clients who are nonresident aliens contemplating residency/citizenship changes

About Presenter

Patrick McCormick, DL, LLM

Advisor,Culhane Meadows

pmccormick@culhanemeadows.com

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

www.culhanemeadows.com

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.

Review Questions

Question 1 : 16:32
Question 2 : 33:16
Question 3 : 48:48
Question 4 : 68:36
Question 5 : 83:24

Review Questions
Final Quiz

Under default rules nonresident aliens are generally subject to United States tax on which one of the following?
- Income effectively connected with a United States trade or business.
  Under default rules nonresident aliens are generally subject to United States tax on (1) income effectively connected with a United States trade or business, and (2) fixed or determinable annual or periodic income.
- Fixed or determinable annual or periodic income.
  Under default rules nonresident aliens are generally subject to United States tax on (1) income effectively connected with a United States trade or business, and (2) fixed or determinable annual or periodic income.
- Both A and B.
  Under default rules nonresident aliens are generally subject to United States tax on (1) income effectively connected with a United States trade or business, and (2) fixed or determinable annual or periodic income.
- None of A and B.
  Under default rules nonresident aliens are generally subject to United States tax on (1) income effectively connected with a United States trade or business, and (2) fixed or determinable annual or periodic income.
According to the detailed sourcing rules for the income earned by nonresident aliens, which one of the following is true?
- Rent/royalties sourced to the place of use of the asset
  True: According to the detailed sourcing rules for the income earned by nonresident aliens, Rent/royalties sourced to the place of use of the asset; and Personal services sourced to where services performed.
- Personal services sourced to where services performed
  True: According to the detailed sourcing rules for the income earned by nonresident aliens, Rent/royalties sourced to the place of use of the asset; and Personal services sourced to where services performed.
- Rent/royalties sourced to the home country only
  True: According to the detailed sourcing rules for the income earned by nonresident aliens, Rent/royalties sourced to the place of use of the asset; and Personal services sourced to where services performed.
- Both A and B.
  True: According to the detailed sourcing rules for the income earned by nonresident aliens, Rent/royalties sourced to the place of use of the asset; and Personal services sourced to where services performed.
On account of which of the following, nonresident aliens have a narrower scope for income tax purpose as compared to the residents or citizen?
- Nonresident aliens are not subject to United States taxes on non-US sourced gains or income.
  nonresident aliens have a narrower scope for income tax purpose as compared to the residents or citizen. The reasons are Nonresident aliens are not subject to United States taxes on non-US sourced gains or income; and United States citizen or residents are subject to tax on income earned worldwide in the US.
- United States citizen or residents are subject to tax on income earned worldwide in the US.
  nonresident aliens have a narrower scope for income tax purpose as compared to the residents or citizen. The reasons are Nonresident aliens are not subject to United States taxes on non-US sourced gains or income; and United States citizen or residents are subject to tax on income earned worldwide in the US.
- None of A and B.
  nonresident aliens have a narrower scope for income tax purpose as compared to the residents or citizen. The reasons are Nonresident aliens are not subject to United States taxes on non-US sourced gains or income; and United States citizen or residents are subject to tax on income earned worldwide in the US.
- Both A and B.
  nonresident aliens have a narrower scope for income tax purpose as compared to the residents or citizen. The reasons are Nonresident aliens are not subject to United States taxes on non-US sourced gains or income; and United States citizen or residents are subject to tax on income earned worldwide in the US.
Which one of the following is an exception to the rule: Foreign-domiciled entities generally are able to elect their entity classification for United States Tax purposes.
- S-Corporations
  As per the regulations Per-se Corporations represent the exception to the following rule: Foreign-domiciled entities generally are able to elect their entity classification for United States Tax purposes.
- C-Corporations
  As per the regulations Per-se Corporations represent the exception to the following rule: Foreign-domiciled entities generally are able to elect their entity classification for United States Tax purposes.
- Per-se Corporations
  As per the regulations Per-se Corporations represent the exception to the following rule: Foreign-domiciled entities generally are able to elect their entity classification for United States Tax purposes.
- None of the above.
  As per the regulations Per-se Corporations represent the exception to the following rule: Foreign-domiciled entities generally are able to elect their entity classification for United States Tax purposes.
HNIs benefit from income acceleration. Such gains become part of their taxable income. The current lifetime exclusion according to the speaker is
- $11.2 Million
  HNIs benefit from income acceleration. Such gains become part of their taxable income. The current lifetime exclusion according to the speaker is $11.4 Million
- $11.4 Million
  HNIs benefit from income acceleration. Such gains become part of their taxable income. The current lifetime exclusion according to the speaker is $11.4 Million
- $11.3 Million
  HNIs benefit from income acceleration. Such gains become part of their taxable income. The current lifetime exclusion according to the speaker is $11.4 Million
- $11.5 Million
  HNIs benefit from income acceleration. Such gains become part of their taxable income. The current lifetime exclusion according to the speaker is $11.4 Million

Minimum 70% Questions answer should be right.

Generally, NRAs are subject to United States tax only on income items sourced to the ___________.
- United States
- Worldwide
- None of the above.
- Their home country.
According to the undefined term trade or business which of the following characteristics are important for the activities conducted in the United States?
- Regularity and a substantial part of the activity
- Continuity of operations
- Both A and B.
- None of the above.
Other than FIRPTA, the nonresident aliens generally are not subject to _______ tax on the United States sourced income.
- Federal Income tax
- Capital Gains Tax
- State Income tax
- FICA and other payroll taxes
The nonresident aliens are subject to ___% of gift tax for the intangible properties received as a gift.
- 40%
- 20%
- 5%
- 0%
Which of the following is true?
- For the entity elections made on the Form 8832, all the entities are required to have an initial election within the first 71 days of entity becoming relevant.
- For the entity elections made on the Form 8832, all the entities are required to have an initial election within the first 73 days of entity becoming relevant.
- For the entity elections made on the Form 8832, all the entities are required to have an initial election within the first 75 days of entity becoming relevant.
- For the entity elections made on the Form 8832, all the entities are required to have an initial election within the first 77 days of entity becoming relevant.
Which of the following exception needs to be kept in mind while considering gifts to family members for the US tax for the pre-immigration tax planning?
- For the noncitizen spouses unlimited marital exclusion does not apply.
- For the non-resident spouses marital exclusion does not apply.
- For the noncitizen spouses unlimited marital exclusion is applicable.
- For the nonresident spouses marital exclusion is applicable.
Which of the following type of trusts are good options for the transfer tax planning for the pre-immigration?
- Foreign Trusts
- Domestic Trusts
- Drop-off Trust
- None of the above
Why private placement life insurance is especially appealing for the transfer tax planning in the preimmigration context?
- It permits a range of investment options.
- It is easier for accessing funds as compared to traditional life insurance policies.
- Both A and B.
- None of the above.

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Reviews

(1)

100%

LL

Linda Lee , CPA

Jul 2nd 2019

Patrick spoke in a fluent manner and presented at a reasonable pace. The presentation materials were easy to read and understand. It was an informative webinar for tax planning strategies.

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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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upcoming On-Demand Webinars

EMAIL EXTINGUISHER - SIMPLE STEPS TO SHRINK THE INBOX

Friday, September 13, 2019 View Details/Register

DOES YOUR CLIENT OWN SHARES IN FOREIGN CORPORATION? IMPACT OF TJCA

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BIGGEST DISRUPTION IN STAFFING FOR ACCOUNTING FIRMS

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INTERNATIONAL TAX: CONCEPTS IN A GLOBAL SOCIETY

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INTERNATIONAL TAX FOR THE GROWING BUSINESS

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CYBERSECURITY – DO’S AND DON’TS in 2019

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The Real Truth about Reverse Mortgages

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ACCOUNTING & CPA FIRMS - TRANSFORM #1 CHALLENGE OF STAFFING INTO AN OPPORTUNITY

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CALSAVERS - CALIFORNIA'S MANDATORY RETIREMENT PROGRAM

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OUR NATIONAL RETIREMENT CRISIS AND THE COSTS TO EMPLOYERS

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Analytics-Based Corporate Performance Management (CPM)

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Risk Management Basics and Developing Risk Management Process

Wednesday, October 02, 2019 View Details/Register

Cost $14
CPE Credits 1.5
CE Credits 1
IRS Course ID GEHNZ-T-00007-19-S
CTEC Course ID 6273-CE-0037
Subject Area Taxes
Course Level Basic
Instructional Method QAS Self Study
Prerequisites None
Advanced Preparation None
Recorded Date September 13 ,2019
Published Date September 13 ,2019
Who should attend? Enrolled Agent Finance Pros Tax Attorney Tax Practitioners CFO/Controller Tax Pros Auditors Tax Firm
Handout Material Download
Key Terms Download

upcoming On-Demand Webinars

EMAIL EXTINGUISHER - SIMPLE STEPS TO SHRINK THE INBOX

Friday, September 13, 2019 View Details/Register

DOES YOUR CLIENT OWN SHARES IN FOREIGN CORPORATION? IMPACT OF TJCA

Friday, September 13, 2019 View Details/Register

BIGGEST DISRUPTION IN STAFFING FOR ACCOUNTING FIRMS

Friday, September 13, 2019 View Details/Register

INTERNATIONAL TAX: CONCEPTS IN A GLOBAL SOCIETY

Friday, September 13, 2019 View Details/Register

INTERNATIONAL TAX FOR THE GROWING BUSINESS

Friday, September 13, 2019 View Details/Register

CYBERSECURITY – DO’S AND DON’TS in 2019

Friday, September 20, 2019 View Details/Register

The Real Truth about Reverse Mortgages

Friday, September 27, 2019 View Details/Register

ACCOUNTING & CPA FIRMS - TRANSFORM #1 CHALLENGE OF STAFFING INTO AN OPPORTUNITY

Friday, September 27, 2019 View Details/Register

CALSAVERS - CALIFORNIA'S MANDATORY RETIREMENT PROGRAM

Friday, September 27, 2019 View Details/Register

OUR NATIONAL RETIREMENT CRISIS AND THE COSTS TO EMPLOYERS

Friday, September 27, 2019 View Details/Register

HOW TO BECOME THE TOP ACCOUNTANT IN TODAY'S WORLD

Friday, September 27, 2019 View Details/Register

THE BIG DEBATE: PASSIVE VS. ACTIVE INVESTING

Friday, September 27, 2019 View Details/Register

Analytics-Based Corporate Performance Management (CPM)

Friday, September 27, 2019 View Details/Register

MEASURING AND MANAGING CUSTOMER PROFITABILITY

Friday, September 27, 2019 View Details/Register