Pre-Immigration Tax and U.S. Investment Planning for High Net Worth Individuals
Navigating the EB-5 Investor Visa Program, Leveraging Tax Credits, and Avoiding Tax Traps
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Thursday, September 10, 2020
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This CLE/CPE course will provide tax counsel and advisers with a comprehensive guide to the tax and investment planning challenges and opportunities for high net worth foreign clients seeking to immigrate to the United States. The panel will discuss strategies for minimizing the U.S. tax impact of foreign-source ordinary and capital income before establishing tax residency in the U.S., detail the current EB-5 program for nonresidents seeking to establish permanent residency through investment in the U.S. economy, outline the tax issues that can arise from participating in the EB-5 program and discuss alternative immigration investment options that may be more tax friendly.
Mr. Klasko has practiced immigration law exclusively over three decades.
Mr. Dudley, is a Managing Director in the Firm’s International Tax group, specializes in developing cross-border commercial structures and financing strategies to optimize international operations and transactions. With over 25 years of public accounting and investment advisory experience, his clients have ranged from Fortune 50 multinational corporations to private equity and hedge funds, small businesses, and start-ups. Mr. Dudley has advised clients in industries as diverse as banking and finance, technology, real estate, infrastructure, manufacturing, and pharmaceuticals.
Mr. Martin advises clients on a variety of tax related matters including international tax planning and related international law matters. His practice focuses on representing foreign clients, multi-national families, international athletes, entertainers and entertainment groups in worldwide investments and financing structures, international tax treaty planning strategies and planning worldwide income, estate and inheritance tax. Mr. Martin is also experienced in resolving and planning for international tax controversies and developing international wealth preservation structures.
Mr. Estefan's practice focuses on the international tax consequences of cross-border investments and has broad experience with international tax planning and compliance. He commonly advises clients on a variety of U.S. international tax issues including the application of U.S. anti-deferral regimes (i.e., GILTI, Subpart F, and PFICs), foreign tax credit planning, tax treaty planning, and post-U.S. tax reform repatriation planning.
The United States is seen as a tax haven for high net worth foreign individuals, even as U.S. corporations invert to lower tax destinations. The U.S. resistance to additional banking disclosure rules is reinforcing America's image as the ultimate destination for many wealthy immigrants. This creates an opportunity for tax counsel and advisers to provide critical income and transfer tax planning to minimize the U.S. tax impact of preexisting foreign assets and to help design an immigration strategy through investment in the U.S.
Because the U.S. imposes tax on its residents' worldwide income, preserving the financial wealth of would-be immigrants to the U.S. may depend on accelerating income and gains and deferring deductions/losses before establishing U.S. residency. This is a desirable strategy if the U.S. statutory tax rate is higher than the immigrant's current tax home, but tax counsel must be aware of the impact on after-tax holdings.
Another critical aspect of pre-immigration planning is assisting clients with establishing U.S. residency and gaining immigration priority by applying for an EB-5 investor visa. This requires a substantial investment in a U.S. trade or business in which the immigrant would take an active role. Tax advisers need to thoroughly understand the requirements of this program to assist clients in the application process.
Listen as our experienced panel provides a thorough guide to the nuances of pre-immigration tax planning, offering practical tips to help assist high net worth clients transition into the U.S. in a tax-efficient manner.
- Residency and tax consequences
- Pre-immigration planning goals
- Avoiding anti-deferral rules
- Minimizing transfer tax impact
- EB-5 visa program and tax considerations
- EB-5 and new markets tax credits
The panel will review these and other essential issues:
- What is the impact of COVID-19 to foreign individuals seeking to become U.S. residents?
- What are the crucial considerations in wealth preservation for a foreign individual becoming a U.S. resident for tax purposes?
- How to avoid anti-deferral rules in pre-immigration transactions
- How to navigate the EB-5 program through a regional center
Learning Objectives
After completing this course, you will be able to:
- Identify the critical tax issues involved in pre-immigration tax planning
- Recognize when to accelerate income and gains
- Determine how to design an asset transfer strategy to minimize U.S. taxation on preexisting foreign-based assets
- Ascertain the steps to the EB-5 investor visa program
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure, international tax law implications, and state and local tax rules.
Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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