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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, January 23, 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.

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

$347.00
CLE
CPE
ALL

This CLE/CPE webinar will provide tax counsel and advisers with a comprehensive look at critical planning issues and tasks for U.S. citizens planning to expatriate, including U.S. taxpayers planning to renounce their citizenship, and green card holders and other foreign citizens with long-standing U.S. tax presence and/or filing requirements. The webinar will address the "exit tax," detail steps to minimize the tax impact of expatriating, and outline the filing requirements both before and after expatriation.

Faculty

Anthony V. Diosdi
Partner
Diosdi & Liu, LLP

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.

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Kerrin N.T. Liu
Partner
Diosdi & Liu, LLP

Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court.  Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.

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Description

The number of U.S. citizens expatriating from the United States has increased at an annual rate of 20 percent over the past few years. As part of Treasury's effort to eliminate tax avoidance through expatriation, Section 877A imposes various taxes on U.S. taxpayers who renounce their citizenship or a long-held green card.

Understanding the expatriation rules contained in Section 877A is critical for lawyers and tax advisers who counsel U.S. taxpayers with cross-border ties. Section 877A creates an exit tax regime for U.S. taxpayers who renounce their citizenship, have intentionally relinquished their U.S. citizenship when they become naturalized citizens of another country, or surrender a green card held for more than seven years and whose income or net worth exceeds specific thresholds. The exit tax rules also apply to expatriates who fail to certify U.S. income tax compliance for the five years preceding the year of expatriation.

The exit tax regime under Section 877A imposes an accelerated tax on unrealized capital gains and types of deferred compensation. The exit tax rules also impose harsh gift and estate taxes on U.S. heirs of those impacted by the law.

Listen as our experienced panel provides a comprehensive and practical guide to navigating the exit tax regime for U.S. citizens planning expatriation.

Outline

  1. Who is a covered expatriate?
    1. The three tests
    2. The exceptions
    3. Determining net worth when trust assets are involved
  2. Applicable taxes under Section 877A
  3. The inheritance tax under Section 2801
  4. Planning techniques

Benefits

The panel will review these and other compelling issues:

  • Who is impacted by Section 877A?
  • How to calculate the mark-to-market tax on capital gains?
  • What types of deferred compensation are subject to the exit tax?
  • The effect of the expatriation rules on U.S. gift and estate taxes
  • Strategies for avoiding or minimizing the taxes imposed under Section 877A

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand the rules and requirements of Section 877A
  • Discern methods in calculating the mark-to-market tax on capital gains
  • Recognize the types of deferred compensation subject to an exit tax
  • Acquire strategies for avoiding or minimizing the taxes imposed under Section 877A

  • 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).