BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Monday, December 9, 2024

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

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

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This webinar will review the initial considerations of obtaining a green card and how to successfully abandon or revoke the same. Our panel of seasoned foreign immigration experts will detail which taxpayers are the best candidates for green cards, when a VISA is a better alternative, the eight of 15-year test for long-term residents, how U.S. treaties affect expatriation, and tax and estate planning for a U.S. exodus.

Faculty

Melvin A. Warshaw
Attorney
Melvin A. Warshaw

Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S. and non-U. S. high net worth individuals, families and companies on a wide range of personal and business tax matters, especially in connection with cross-border income and estate tax planning and compliance in the U. S. Mr. Warshaw is admitted to practice in the Commonwealth of Massachusetts. He regularly advises non-U. S. clients on structuring inbound pre-immigration tax strategies including basis step-up in legacy assets, avoiding the U. S. CFC and PFIC anti-deferral tax regimes, optimizing use of foreign tax credits, minimizing green card status as well as advising on and drafting of “drop-off trusts.”  Mr. Warshaw also advises long-term green card holders and U. S. citizens on planning to minimize their U. S. exit tax through gift programs, managing equity compensation and by drafting “expatriation” trusts and considerations of a change of domicile outside the U. S. He has also counseled clients in complying with their U. S. tax filing obligations by engaging accountants and bringing such taxpayers into compliance with their numerous U. S. international tax reporting requirements. Mr. Warshaw has also advised on the U. S. international tax aspects of cryptocurrency, including how to become U. S. tax compliant and how to mitigate U. S. tax implications prior to and following renouncing U. S. citizenship.

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David Lesperance
Founder and Principal
Lesperance & Associates

Mr. Lesperance is one of the world’s leading international tax and immigration advisors. He has successfully advised scores of high and ultra high net-worth individuals and their families, many of whom continue to seek his counsel today. In addition Mr. Lesperance has provided pro bono advice to many governments on how to improve their Citizenship by Investment, Residence by Investment or “Golden Visa” type programs to better meet the needs of his global clients. He is supported by a team of professionals, some of whom have worked with him since the early 1990s.

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Description

A U.S. person is taxed on worldwide income and is likewise subject to foreign information return reporting and the U.S. estate tax regime. Unfortunately, international tax advisers often are not consulted by taxpayers until after they have obtained their coveted green card. Holding a green card can trigger unexpected tax and filing obligations. Now considered a U.S. shareholder, a green card recipient with shares held in foreign corporations could be unwittingly subjected to CFC (controlled foreign corporation) or PFIC (personal foreign investment company) reporting and tax requirements. Additionally, inheritances from family abroad could be included in the resident's taxable estate.

The process to abandon or revoke is often more painful than the reporting obligations that come with the green card. Covered expatriates, including individuals exiting with a net worth of at least $2 million, must pay an exit tax on the fair market value of worldwide assets above $866,000 (2024). Appropriate planning can negate or mitigate these harsh income and estate taxes.

Listen as our panel of international tax experts explains the tax consequences of green cards, including pre-planning and revocation considerations.

Outline

  1. Green cards vs non-immigrant VISAs
  2. Pathways to a green card
  3. Pre-immigration tax planning
  4. Naturalisation or not
  5. Covered expatriate implications of long-term green card residency
  6. Strategies to avoid covered expatriate status ramifications of staying too long
  7. Implications of being a covered expatriate
    • Exit tax
    • Inheritance tax
    • Pre-expatriation tax planning
    • War stories

Benefits

The panel will cover these and other critical issues:

  • When should a green card holder file Form I-407, Record of Abandonment of Lawful Permanent Resident Status?
  • How can gifting be used to lower expatriation taxes?
  • Tips to present long-term resident status to expedite expatriation
  • How do U.S. treaties affect expatriation?
  • When is a green card holder subject to the CFC taxation regime?
  • What is the eight of 15-year rule, and how does it affect expatriation?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify the differences between green cards and non-immigrant visas
  • Recognize the pathways to a green card
  • Develop strategies to avoid covered expatriate (CE) status
  • Understand the ramifications of overstaying the green card period
  • Ascertain the planning concerns for pre-immigration transfer taxes
  • Determine the implications of long-term green card residency

  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).