Portugal as a Destination for UK, U.S., and Other Tax Residents: Latest Immigration and Tax Strategies
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Thursday, September 26, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This webinar will review the impact of recent significant changes to Portugal's tax guidelines and the impact of these changes on immigrants. Our panel of international wealth transfer veterans will discuss the tax ramifications of expatriating and residing in Portugal for U.S., UK, and other countries who are anticipating a move. Their presentation will include multiple case studies of taxpayers relocating to Portugal and the tax considerations and effects of their relocations.
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.
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.
Mr. Master acts for some of the Firm's largest private clients and heads our Private Wealth Sector. He acts for high net worth individuals from across the world, but especially from the Middle East, where he acts for many ruling family members and billionaires – many of whose families have US links. Mr. Master's work for these families includes advising on the establishment of global assets holding structures, family governance projects and global real estate investments. He is a Visiting Professor at the University of Law, a Council Member of the International Academy of Estate and Trust Law, and an International Fellow of the American College of Trust and Estate Counsel. Mr. Master's lectures regularly in the UK and internationally on matters of private client interest. He has been featured in eprivateclient’s 50 Most Influential listing, the definitive listing of leading private wealth lawyers, in 2021, 2022 and 2023. Mr. Master's is admitted to practise in England and Wales.
Mr. Barnabé is a Partner and has been at Abreu Advogados since 2019, working in the tax area with a focus on Private Clients, Wealth and Succession. With over 20 years’ experience in tax law, Mr. Barnabé is a specialist in wealth taxation and estate planning, advising private clients, family offices, private banks and asset managers in Portugal and Portuguese-speaking African countries and cross-border Switzerland, UK and US. Mr. Barnabé is a dual qualified lawyer in Portugal and Switzerland (EU Lawyer). He is also a founder of the Portuguese Tax Arbitration Tribunal. He is a member of the International Fiscal Association, the International Bar Association (Taxes and Private Client Tax Committees), The Society of Trust and Estate Practioners (STEP – TEP, International Client SIG), the International Academy of Estate and Trust Law (TIAETL), the American College of Trust and Estate Counsel (ACTEC) and the American Bar Association (ABA).
Tax professionals working with multinational taxpayers need to comprehend the recent tax changes to advise clients considering leaving their current tax home and establishing one in Portugal. The country has long been a popular destination for immigrants by offering incentives and a favorable taxation regime for foreigners. Recent changes to immigration and tax laws certainly give those immigrating or considering migrating from the U.S., UK, or other countries new considerations to weigh. Historically, Portugal has welcomed expats. The Non-Habitual Resident (NHR) program is not available as of Jan. 1, 2024, although those who previously qualified will be able to benefit for the 10-year term. But a new program was enacted which continues to provide for a foreign source income exemption in general and a tax rate of 20 percent for selected expatriates. Considering the top tax rate in Portugal for salaries is 48 percent and begins at only 81,199 EUR of taxable income and that passive income is generally taxed at 28 percent, the new program is a welcome tax relief for those who qualify.
Furthermore, the Golden Visa program and other residence paths still exist, with revisions. Purchasing property in Portugal is no longer a Golden Visa option, but investments of 500,000 EUR. in approved funds still is a pathway. In addition, those who are willing to spend more than 6 months in Portugal or invest in startup business opportunities can also obtain residence.
Americans must deal with the unique feature of the US tax system which imposes income tax on worldwide income and estate tax on worldwide assets of its citizens as well as its residents. For Americans living abroad, they must rely on relevant tax treaties to try to mitigate double tax of the same income. For Americans who are considering expatriating, they must manage and plan for the draconian U.S. exit tax and inheritance tax regimes applicable when an American citizen or long-term resident expatriates.
Listen as our panel of immigration and taxation experts explains Portuguese immigration options and the tax effects of residing in Portugal for multinational citizens.
- Portugal: tax considerations for immigrants
- Motivations of non-doms and UK domiciliaries under the new Labour government
- Motivations for Americans considering living abroad or expatriating
- Motivations for taxpayers of other countries such as France, Canada, and South Africa
- Portugese immigration options
- Digital nomad
- D7
- Golden Visa
- Portugal tax planning options
- Case studies
- UK non-dom
- UK dom
- American living abroad
- American expatriating
The panel will cover these and other critical issues:
- Immigration options including Golden Visas
- Portugal's new tax guidelines for foreigners
- Tax considerations of U.K. non-doms and doms relocating to Portugal
- Tax considerations of Americans expatriating or relocating to Portugal
- Case studies including the tax impact of foreigners moving to Portugal
Learning Objectives
After completing this course, you will be able to:
- Identify immigration options in Portugal for foreigners
- Determine why non-doms would be motivated to relocate to Portugal
- Decide how expats are taxed in Portugal under the new rules
- Ascertain differences between Portugal's prior and current taxation of immigrants
- 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.
Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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