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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

    Wednesday, March 8, 2023

  • 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 standard provisions in U.S. estate and gift tax treaties and explore specific provisions in treaties with particular countries that can be utilized to reduce or eliminate exposure to U.S. transfer taxes.

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

An individual foreign investor's estate or donative transfer is subject to gift and estate tax at the same rates as U.S. residents. The current unified credit for foreigners, however, is only $60,000 compared to the $12.92 million (2023) exemption available to U.S. citizens and residents. U.S. residents often use the marital deduction to mitigate these extreme taxes; however, the rules for the marital deduction differ substantially for nonresidents. Whether or not an individual is a resident or domiciled in the U.S. significantly affects the impact of transfer taxes.

U.S. estate and gift tax treaties can be utilized to significantly reduce estate and gift tax exposure. The U.S. has estate or gift tax provisions in treaties with at least 15 countries, including Australia, France, Japan, and the United Kingdom. These treaties generally provide for more generous estate and gift tax exemptions and sometimes allow nonresidents to claim a marital credit. Understanding the ins and outs of general U.S. estate and gift tax treaty provisions and the U.S.' treaties with particular countries can reduce transfer tax liability for multinational taxpayers.

Listen as our panel of international tax attorneys explores common provisions in U.S. estate and gift tax treaties for estate and trust advisers.

Outline

  1. U.S. estate and gift tax treaties: introduction
  2. Residency and domicile
  3. Special estate and gift tax treaty provisions
  4. Marital deduction
  5. Situs rules
  6. Charitable deductions
  7. Competent authority requests
  8. Disclosure of treaty-based return positions
  9. Specific provisions by country
    1. U.S.-Canada Income Tax Treaty
    2. United Kingdom
    3. Denmark
    4. Other countries

Benefits

The panel will cover these and other critical issues:

  • How U.S. residency impacts inheritance taxes
  • Filing competent authority requests to resolve treaty interpretation disputes
  • Utilizing marital deductions for U.S. residents and nonresidents
  • Disclosing treaty-based return positions
  • Utilizing specific provisions in treaties to mitigate estate and gift taxes

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Determine how a competent authority request is used to settle disputes
  • Decide how U.S. residency impacts estate planning
  • Ascertain marital deduction differences for U.S. residents and nonresidents
  • Identify key provisions in international estate tax treaties

  • 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 estate, gift and trust taxation including various trusts types, the unified credit, and portability.

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).