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Course Description

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.

Learning objectives

  • Awareness of income tax rules applicable to non-resident aliens.
  • Awareness of transfer tax rules applicable to non-domiciliaries.
  • Techniques for ownership of U.S. sitused assets by non-U.S. taxpayers.

About Presenter

Patrick McCormick, JD, LLM

Partner, Culhane Meadows, PLLC

[email protected]

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.

Refund/Cancellation Policy

For more information regarding refund, complaint and program cancellation policies, please contact our offices at 646-688-5128

NASBA Approved

MY-CPE LLC, 1600 Highway 6 South, Suite 250, Sugar Land, TX, 77478

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.

IRS Approved

MY-CPE LLC, 1600 Highway 6 South, Suite 250, Sugar Land, TX, 77478

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

upcoming Live CPE Webinars

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Thursday, October 17, 2019 | 11:30 AM EDT View Details/Register
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IRS Tax Practice and Procedure Introduction
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  • Cost FREE
  • CPE Credits 1.5
  • CE Credits 1
  • Course ID GEHNZ-T-00027-19-O
  • Subject Area Taxes
  • Course Level Basic
  • Instructional Method group internet based
  • Prerequisites None
  • Advanced Preparation None
  • Who should attend? Enrolled Agent Finance Pros Tax Attorney Tax Practitioners Accountant CFO/Controller Others CPA - Small Firm CPA - Mid Size Firm Accounting Firm Tax Pros CPA (Industry) Auditors Tax Firm Young CPA CPA in Business Entrepreneurial CPA
  • Handout Material Download

upcoming Live CPE Webinars

SMARTER SOCIAL SECURITY
Thursday, October 17, 2019 | 11:30 AM EDT View Details/Register
The 5 steps for attracting $3K-$15K high-profit, monthly clients
Thursday, October 17, 2019 | 12:00 PM EDT View Details/Register
Financial fraud and operational risks - 2019 Edition
Thursday, October 17, 2019 | 01:00 PM EDT View Details/Register
The Top Seven Trends in Management Accounting
Thursday, October 17, 2019 | 02:30 PM EDT View Details/Register
IRS Tax Practice and Procedure Introduction
Friday, October 18, 2019 | 10:00 AM EDT View Details/Register