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Course Details

Course Information
  • smart_display Format

    Live Online with Live Q&A

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, June 24, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax counsel and compliance professionals guidance on U.S. tax rules, reporting requirements, and available tax planning mechanisms for foreign individuals and businesses. The panel will offer approaches for determining taxpayer classification and engaging in U.S. trade or business under current tax law, identifying and reporting income subject to U.S. income tax, and understanding the impact of tax treaties, available exemptions, and deductions. The panel will also offer U.S. tax planning tips for foreign individuals and businesses with activities within the United States.

Faculty

Gregory M. Weigand
Partner
McDermott Will & Emery, LLP

Mr. Weigand focuses his practice on complex domestic and international tax matters for multinational companies, closely held businesses, investment funds and family offices and high-net-wealth individuals. He advises US and foreign-based publicly traded and privately held companies on domestic and international mergers and acquisitions, financing transactions, and global restructuring transactions. Mr. Weigand regularly advises on the tax aspects of complex domestic and international transactions and the formation, structuring, and operation of private equity funds and family offices. He is experienced in negotiating, drafting and documenting transactions involving corporations, partnerships and cross-border entities. In addition, Mr. Weigand regularly represents international businesses and individuals with structuring and reorganizing their US operations and investments, including a significant amount of US real estate-based transactions such as the purchase and sale of commercial real estate and hospitality-related assets.

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Description

Foreign individuals and businesses engaging in transactions or having assets and activities in the U.S. create tax presence and residency issues for such businesses and individuals. Tax professionals and advisers must have a solid understanding of U.S. tax treaties and applicable rules for foreign individuals and businesses and their interplay with current U.S. tax law.

Generally, noncitizens or non-U.S. enterprises with U.S. investments or business activities are subject to U.S. income tax only on their U.S.-sourced income, requiring tax advisers to conduct a careful analysis to determine their taxpayer status, connection to the U.S., eligibility for tax treaty benefits, and approaches to reduce their tax liability and U.S. reporting obligations.

For foreign businesses, the critical issue is whether nonresident employees currently present in the U.S. give rise to a U.S. trade or business or a permanent establishment for the foreign employer. Similarly, foreign individuals can be treated as U.S. residents for tax purposes if they meet the "substantial presence test."

Listen as our panel guides tax professionals and advisers in determining taxpayer status for non-U.S. citizens and businesses, reporting requirements and available mechanisms under current U.S. tax law, and best practices for taxpayers.

Outline

  • U.S. tax presence and residency rules
  • Tax issues for non-U.S. individuals
  • Tax issues for non-U.S. businesses
  • Compliance and reporting challenges for taxpayers


Benefits

The panel will review these and other key issues:

  • What is the impact of tax presence and residency of individuals and businesses?
  • What is the impact of the application of the "substantial presence test"?
  • What are the key issues stemming from the application of the "physical presence test" for purposes of determining U.S. trade or business or permanent establishment standards?
  • What allocation issues are present?
  • What are the steps to overcome regulatory and compliance challenges?



NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the impact of U.S. tax presence and residency rules for individuals and businesses
  • Identify key provisions and issues associated with recent IRS guidance and regulations
  • Recognize allocation issues associated with U.S. and non-U.S. businesses with employees working away from their home jurisdiction
  • Ascertain methods for managing potential nonresident audits and overcoming other regulatory, reporting, and compliance challenges


  • 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, supervising other preparers/accountants. Specific knowledge and understanding of Effectively-Connected Income (ECI) and FDAP rules; familiarity with taxpayer residence and presence tests

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.