Understanding Expatriation and the Exit Tax

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.

Presenters:

Gary Forster, JD, LLM (Tax)

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 ?rst 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...Read more about Gary Forster here

J. Brian Page

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...Read more about J. Brian Page here

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