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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

    Tuesday, December 3, 2024

  • 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 tax professionals guidance on key U.S. tax planning strategies available to foreign nationals and pitfalls to avoid. The panel will discuss key considerations for resident and nonresident aliens for U.S. tax purposes, sourcing of income and challenges that disrupt tax planning, available exemptions and the use of tax treaties, and U.S. tax planning tips for foreign nationals.

Faculty

C. Edward Kennedy
Managing Director
C Edward Kennedy Jr, PC

Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.

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Michael Dana
Partner
Husch Blackwell LLP

Mr. Dana provides tax and corporate law advice to businesses at all phases of operation, from initial business formation to disposition and all points in between. He advises clients across virtually all areas of operation regarding U.S. federal income tax issues. Mr. Dana has represented U.S.-based, foreign-based, and multinational enterprises, providing advice in connection with acquisitions, distribution structures, and internal reorganizations, including complex crossborder transactions; U.S. Subpart F income and GILTI planning and analysis; foreign tax credit planning and analysis; tax treaty analysis, and other matters related to outbound and inbound U.S. tax planning. His representations have included business structures, operations, and investments by US clients in, or by non-US clients from, Europe, Canada, Latin America and a number of other jurisdictions outside of the U.S. He also works with closely held businesses and their owners to develop and implement tax strategies that protect and enhance corporate value.

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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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Description

There are many foreign nationals who own property, earn income, or receive dividends stemming from their activities in the United States. These foreign nationals are subject to a variety of U.S. tax rules which require effective planning to minimize or avoid adverse tax implications. Tax professionals must navigate complex U.S. tax rules applicable to these foreign nationals and conduct a careful analysis to determine their taxpayer status, connection to the U.S., and approaches to reduce their tax liability.

A foreign national can be subject to different U.S. tax regimes depending on whether they are classified as a resident or a nonresident alien. While being classified as a nonresident alien of the U.S. provides distinct tax advantages, being classified as a resident alien may provide better tax benefits under certain circumstances. It's imperative that potential tax liability and available tax planning options be considered on an annual basis.

In addition, tax professionals must consider a variety of issues in order to implement adequate planning for foreign nationals subject to U.S. taxation, such as the timing of income recognition, tax basis of assets for U.S. tax purposes, unrealized appreciation or loss, and other key issues. Tax treaties, deductions, credits, and other options may be available to reduce or eliminate the applicable tax rates or liability.

Listen as our panel discusses key considerations for resident and nonresident aliens for U.S. tax purposes, sourcing of income and challenges that disrupt tax planning, available exemptions and the use of tax treaties, and U.S. tax planning tips for foreign nationals.

Outline

  1. Rules and regulations regarding foreign nationals and U.S. income tax system
  2. Determining taxpayer status, filing, and reporting requirements
  3. Income sourcing and classification
  4. Tax treaties and reducing or eliminating U.S. tax on income
  5. Best practices for compliance and tax planning techniques for foreign nationals

Benefits

The panel will review these and other high priority issues:

  • U.S. tax rules and regulations applicable to foreign nationals
  • Determining resident and nonresident alien status
  • Differences in U.S. tax systems and reporting for resident versus nonresident aliens
  • The effect of tax treaties the U.S. has with other countries
  • U.S. tax planning techniques for foreign nationals and pitfalls to avoid

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Determine the classification and status of a taxpayer as a U.S. resident or nonresident alien
  • Discern the difference between income effectively connected with a U.S. trade or business and fixed, determinable, annual, or periodic income
  • Identify special elections, deductions, and credits available to foreign nationals

  • 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.

IRS Approved Provider

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