International Tax for Immigration Purposes
Author: Patrick McCormick
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2025 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
Pre-Immigration Tax Planning and Expatriation Tax Considerations
There are numerous tax considerations tied to immigration and residency status. When an individual becomes a U.S. citizen, or forfeits that status, there are income tax as well as estate and gift tax implications.
This course reviews the tax and immigration considerations relevant when individuals enter or leave the United States, including a review of pre-immigration concerns for E-2 and other investors commencing American taxpayer status, expatriation tax considerations for individuals renouncing American tax status, and prospective immigration-side options for individuals choosing to reject U.S. taxpayer status. This course will benefit tax attorneys with immigrant clients and immigration attorneys seeking to understand their client's tax issues.
Publication Date: October 2022
Designed For
null
Topics Covered
- Immigration — Basics and Initial Tax Considerations
- Income Tax Comparison — United States Taxpayers Versus Nonresidents
- Estate/Gift Tax Comparison — United States Taxpayers Versus Non domiciliaries
- Pre-Immigration Planning Techniques
- Expatriation and the Exit Tax
Learning Objectives
- Recognize how the United States taxes residents when compared to nonresidents
- Identify pre-immigration tax planning mechanics
- Identify expatriation and how "covered expatriate" status can lead to exit taxes
- Identify where interest and dividend income is sourced to
- Identify the flat rate of tax amount that FDAP income is generally subject to
- Identify the automatic step-up in basis percent for U.S. tax purposes upon commencing U.S. taxpayer status
- Identify the highest applicable tax rate for estate and gift purposes that gifts or bequests are subject to be taxed
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
