International Taxation Update - Post TCJA & COVID-19 & Estate Tax for Non-Residents

CREDITS: 4.5

CATEGORY: Professional Practice

SPEAKER: Scott Ahroni, Esq.

THIS COURSE COMBINES TWO TOPICS INTO ONE AMAZING & INFORMATIVE SEMINAR!

PART 1

With the onset of the pandemic, we are seeing significant cross-border taxation implications emerge, particularly relevant to residency determinations for United States and foreign individuals and businesses. Travel restrictions and “shelter in place” orders have caused the displacement of individuals and employees, inadvertently creating tax residents and permanent establishments in the United States, along with other foreign taxing jurisdictions. The change in employee’s locations has also forced businesses to revisit income sourcing determination.

Recently issued IRS regulations have clarified and modified international tax changes that were originally enacted as part of the Tax Cuts and Jobs Act (“TCJA”). Finally, the IRS continues to make offshore compliance of foreign accounts, assets, pensions and income a key enforcement priority and has issued a campaign to audit taxpayers that previously filed Offshore Voluntary Disclosure Program submissions.

In this presentation, Scott Ahroni will discuss the recent international tax changes that CPAs should be aware of to ensure that their clients have properly reported their cross-border activities. Mr. Ahroni will also advise what an audit will look like in the current environment and the relief provisions available for eligible taxpayers looking to come into compliance with their foreign reporting obligations.

PART 2

Estate planners are increasingly working with expatriates and foreigners regarding their estate and tax planning for their U.S. owned businesses and investments. This seminar will discuss the specific issues of inbound and outbound estate and gift tax planning, as well as, the compliance obligations of imposed on both clients and practitioners engaging in foreign estate plans. Finally, this seminar will discuss the IRS recent audit campaigns targeting foreign investment in the U.S. and what relief provisions are available if you or your client need to come into compliance with information reporting obligations.

Topics & Learning Objectives Include:

Part 1 - Scott Ahroni - International Tax Update

  • Recent Campaign by the IRS Going After Previously Filed Offshore Voluntary Disclosure Programs (OVDP)
  • Non-Resident Filing Rules (1040NR)
  • How to determine U.S. tax residence and possible relief for individuals and workers “sheltering-in-place” in the United States
  • Common issues with preparing Form 1040-NR, Nonresident Alien Income Tax Return, including determination of FDAP and effectively connected income and claiming treaty benefits
  • Tax obligations for residents and non-residents leaving the United States, including a discussion on the “expatriation tax” and FIRPTA
  • How recently issued regulations will impact your client’s income sourcing and foreign tax credit calculations, as well as, their exposure to the GILTI tax
  • Foreign information reporting obligations including FBAR and Forms 5471, 5472 and 8938
  • Possible relief from foreign income and information return reporting compliance through recently revised voluntary disclosure programs

Part 2 - Scott Ahroni & Albert Dumaual - Non-Resident Estate Tax Update

  • How to determine U.S. tax residence for the Estate and Gift Tax
  • Foreign information reporting for foreign gifts and foreign transfers to and distributions from foreign trusts
  • Substantive U.S. estate and gift tax rules relative to foreign investors' planning and tax minimization alternatives including use of foreign trusts, determining the gross estate and taxable gifts, and modifications to the unified credit and marital deduction
  • How to protect your client from increased IRS audit activities in U.S. estate and gift tax areas as they relate to foreign investors
  • Pre-immigration planning to reduce exposure to estate and gift taxes
  • Possible relief from foreign gift and trust reporting compliance through recently revised voluntary disclosure programs

Scott Ahroni and Albert Dumaual both have extensive experience assisting clients with international income, business and estate tax planning as well as, international information returning filings.

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