Course Description
As global nomad increases and the IRS intensifies its oversight of cross-border financial activity, legal advisors must understand the tax implications of residency classification, income sourcing, and treaty application. The course will provide clear guidance on common tax planning opportunities and compliance pitfalls encountered by nonresidents with U.S. ties. Attendees will gain insight into how to navigate IRS disclosure regimes, structure U.S. investments efficiently, and assist clients with immigration- and expatriation-related tax considerations. The discussion will be especially useful for attorneys working with high-net-worth international clients, multinational families, and cross-border real estate or portfolio investors.
Syllabus
- US Tax Residency Rules
- US Tax Treaties (General Discussion)
- IRS Tax Forms and Schedules
- US Non-Resident Effectively Connected Income (ECI) and Non-Effectively Connected Income (NECI)
- Tax Deductions and Federal Credits for US Non-Resident
- US State and Local Tax and Gift & Estate Tax Implications (Generally)
- Pre-Immigration Income Tax Planning (Converting from Non-Resident to Resident)Â