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Structuring United States Investments By Foreign Taxpayers

4.6 (78)

Patrick McCormick, Doc. of Law

Culhane Meadows

Monday, March 16, 2020 | 12:00 PM EDT

  • CPA
  • EA

1.5 Credits


Subject Area


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.


  • Income and branch profits tax
  • FDAP Income
  • Tax Treaties
  • Foriegn Trusts

Join this CPE webinar to understand 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 learn about the income tax rules applicable to non-resident aliens.
  • To learn about the transfer tax rules applicable to non-domiciliaries.
  • To learn the Techniques for ownership of U.S. situated assets by non-U.S. taxpayers.
  • To understand the takeaways from International TJCA

Who Should Attend?

  • Accountant
  • Accounting Firm
  • Auditors
  • CFO/Controller
  • CPA (Industry)
  • CPA - Mid Size Firm
  • CPA - Small Firm
  • CPA in Business
  • Enrolled Agent
  • Entrepreneurial CPA
  • Finance Pros
  • Others
  • Tax Attorney
  • Tax Firm
  • Tax Practitioners
  • Tax Pros
  • Young CPA


    [no_of_record] => 78
    [average] => 4.6282




It was a good overview on the components of foreign taxpayers. The information was useful, but the instructor was hard to understand at times.


Good course, interesting to get unbiased thoughts from someone on "the other side of the table."