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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.
Advisor, McCormick Tax Group, LLC
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.
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