Understanding Expatriation and the Exit Tax
Overview
In this seminar, we explore the income tax consequences of expatriation for U.S. citizens, permanent residents, and their assets. We discuss the development and unravel the intricacies of the deemed sale rules. Attendees will learn effective strategies for minimizing tax and ensuring tax compliance.
Speakers:
Gary A. Forster, J.D., LL.M.
J. Brian Page, J.D., LL.M.
Objectives
Understand U.S. Tax Status Determination:
- Distinguish between U.S. citizens, resident non-citizens, and non-resident aliens (NRAs).
- Identify the tax implications associated with each status.
Comprehend Income Tax Implications:
- Analyze the income tax differences for U.S. citizens, resident non-citizens, and NRAs.
- Learn how income is taxed under different residency statuses.
Grasp Estate and Gift Tax Rules:
- Understand estate and gift tax rules for U.S. citizens and resident non-citizens.
- Examine the differences in estate tax imposition on non-resident non-citizens.
- Develop gifting strategies to minimize tax liabilities for NRAs.
Navigate International Tax Treaties:
- Understand the role of treaties in expatriation and tax compliance.
- Learn how treaties can affect tax obligations and benefits.
Understand Expatriation Process:
- Explore the steps and requirements for expatriation for U.S. citizens and long-term residents.
- Determine the effective date of expatriation and its tax consequences.
Master Expatriation Tax Concepts:
- Understand the "Exit Tax" and "Inheritance Tax" under Sections 877A and 2801.
- Learn how the deemed sale rules and inheritance tax apply to expatriates.
Determine Residency Dates for Tax Purposes:
- Identify the start and termination dates of residency for non-resident aliens.
- Understand the importance of these dates in tax calculations.
Apply Section 877 and 877A Rules:
- Learn the historical and current expatriation tax rules under Sections 877 and 877A.
- Understand the criteria for being classified as a "covered expatriate."
Develop Tax Planning Strategies:
- Explore strategies to mitigate "Inheritance Tax" and other tax liabilities under §2801.
- Learn about potential planning strategies, including gifting, trusts, and domicile planning.
Notice
Leader(s):
Leader Bios
Gary Forster, Managing Partner, ForsterBoughman
Gary's practice includes domestic and international corporate law, asset protection, tax, and estate planning. Gary handles a wide variety of corporate and personal planning matters.
Gary spent the first decade of his career structuring and closing some of the largest corporate transactions in the region. The mergers and acquisitions Gary consummated range from the national consolidation of regional US construction and transportation interests to real estate investment trusts, hospitals and surgical centers. Gary is one of the few attorneys in Central Florida with experience in cross-border corporate transactions, including a variety of industries ranging from intellectual property concerns to international distribution and manufacturing interests.
Gary's corporate work, with some of the most prominent companies and entrepreneurs in Florida and abroad, led him to expand his practice ?fteen years ago. Successful clients require substantial tax, estate and asset protection planning. Gary recognized that certain wealthy clients require a single partner contact, familiar with both business law and tax planning and structuring. Gary serves that purpose. Gary has designed and drafted hundreds of corporate documents and asset protection plans.
Gary is the author of two books. In 2013, he wrote Asset Protection for Professionals, Entrepreneurs and Investors, a guide to asset protection strategies for clients and their ?nancial advisors, now in its second edition. In 2016, Gary finished the ?rst edition of The U.S. Estate and Gift Tax and the Non-Citizen, which explains how resident and non-resident foreign nationals are impacted by the U.S. Estate and Gift Tax.
Gary writes and lectures nationally to state bar and CPA groups on the topics of asset protection, international tax and corporate law. He has also instructed classes at the University of Florida (Levin College of Law) and Rollins College (Crummer Graduate School of Business). Gary's articles can be found in such publications as the Florida Bar Journal and the American Bar Association's Probate and Property Magazine. For a listing of Gary's recent speaking engagements, see below.
Gary's legislative amendments were adopted as Section 43A of the Nevis LLC Ordinance - Nevis Limited Liability Company (Amendment) Ordinance, 2015.
Joseph Page, ForsterBoughman
Brian Page practices in the areas of domestic and international estate planning, domestic and international tax planning, federal and state tax controversy, and probate and trust administration.
Brian has extensive experience developing sophisticated estate plans for wealthy individuals and families. These plans are designed to reduce potential tax burdens within the context of each client’s overall estate-planning objectives. To accomplish
this task, Brian uses sophisticated planning vehicles – including specialized tax planning trusts, family-limited partnerships, limited liability companies, and private foundations - and tailors them to meet his clients’ specific needs. Brian also works with clients to create and implement effective estate plans that take advantage of the laws of foreign jurisdictions.
Brian also advises clients on both domestic and international tax issues. This includes planning for all federal tax issues that might arise for U.S. residents, non-resident aliens, green card holders, and their ownership interests in foreign trusts, corporations, or
other entities. It also encompasses the taxation of foreign trusts, pre-immigration tax planning for non-resident aliens, expatriation tax planning for US residents, the taxation of crypto-currency, and the analysis of federal income and transfer taxes on nonresident
aliens, green card holders, and their families.
In his fiduciary administration practice, Brian works with clients regarding the administration and management of estates and trusts, and he counsels fiduciaries and beneficiaries regarding a wide range of administration and federal tax matters. This includes preparing estate and fiduciary income tax returns and representing fiduciaries before the Internal Revenue Service.
In his tax controversy practice, Brian represents clients in all stages of tax controversy before the Internal Revenue Service and the Florida Department of Revenue. From state sales tax audits to federal backup withholding issues, Brian has extensive experience resolving tax disputes for his clients.
Brian writes and lectures frequently on the topics of estate planning, federal taxation, international taxation, foreign trusts, and pre-immigration planning.
Non-Member Price $45.00
Member Price $39.00