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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

    Wednesday, November 18, 2020

  • 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 course will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes. The panelist will discuss the impact of new tax law on expatriation planning techniques, critical challenges under Section 877A, and guidance on exiting the U.S. tax regime.

Faculty

K. Eli Akhavan
Partner
Grant Herrmann Schwartz & Klinger, LLP

Mr. Akhavan focuses his practice on tax and estate planning for high-net-worth US and non-US clients. He advises domestic and international individuals and families with respect to tax and estate planning for their US assets and beneficiaries. Mr. Akhavan also advises cross-border clients on all aspects of international estate matters, including foreign trusts, pre-immigration and expatriation planning, and on planning for the purchase of US residential and investment real property. He has considerable knowledge of the reporting requirements applicable with respect to foreign financial accounts and assets and with respect to FATCA and its global equivalent, the Common Reporting Standards (CRS). Mr. Akhavan's practice includes advising clients on the formation of private trust companies for purposes of wealth management and privacy.

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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 several 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 K. Eli Akhavan, Senior Counsel at Norton Rose Fulbright US, 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. The taxes applicable to a CE under Section 877A
  3. The inheritance tax under Section 2801
  4. Planning techniques

Benefits

The panelist 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 at mid-level within the organization, preparing complex tax forms, plans and projections, supervising other attorneys. Specific knowledge and understanding of foreign asset reporting requirements; familiarity with beneficial ownership rules, mark-to-market principles, deferred compensation rules, and gift transfer 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.

IRS Approved Provider

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