About the Course
Introduction
This webinar will provide international tax advisers with a practical and technical analysis of the U.S. expatriation rules, including the Section 877A exit tax regime, covered expatriate classification, Form 8854 compliance requirements, and significant 2025 developments affecting gifts and bequests from covered expatriates. Our panel of experienced international tax attorneys will explain how expatriation can trigger immediate income tax consequences, future transfer tax exposure, and complex reporting obligations for both expatriates and their families.
Description
Covered expatriates are subject to tax on the deemed sale of all assets at fair market value. A covered expatriate is anyone who either (1) has a net worth of $2 million or more on the day of expatriation, (2) has an average net income tax for five years before expatriation exceeding $211,000 (2026), or (3) fails to certify compliance with U.S. laws by completing Form 8854.
Recent regulations issued under Section 2801 provide long-awaited rules governing gifts and bequests received by U.S. citizens or residents from covered expatriates. These transfers are taxed at the highest estate and gift tax rate, currently 40%, and the tax is paid by the recipient rather than the expatriate. These rules create new compliance and reporting considerations for taxpayers, beneficiaries, trustees, and advisers.
Listen as our adept panel discusses covered expatriate status, exit tax calculations, Section 2801 inheritance tax rules, and practical planning strategies for international tax practitioners advising high net worth individuals, globally mobile taxpayers, and families facing expatriation-related tax issues.
Presented By
Mr. McCormick is an attorney with fifteen years of experience, focusing his practice on international taxation. He represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at large law firms, an accounting firm, and a boutique tax law firm, Mr. McCormick's client exposures have covered every conceivable area of American-side international tax matters. He has worked with clients located in over 130 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. Mr. McCormick's practice focus has facilitated an unparalleled expertise in the field; he is trusted by clients and advisors around the world to obtain optimal results on international tax matters. Mr. McCormick is licensed to practice in Pennsylvania and New Jersey. and regularly assists clients (particularly multinationals) with estate planning needs in these jurisdictions.
-
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).
Date + Time
- event
Tuesday, August 11, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Expatriation tax planning: introduction
II. Determining covered expatriate status
III. §877A - Tax responsibilities of expatriation
IV. §2801 - Imposition of tax on covered gifts and bequests and January 2025 final regulations
V. Transfer tax exposure
VI. Pre-expatriation planning
The panel will cover these and other critical issues:
- Determining covered expatriate status under the income tax liability, net worth, and certification tests
- Form 8854 filing requirements and common compliance failures
- Mechanics of the Section 877A mark-to-market exit tax regime
- Gifts and bequests from covered expatriates under Section 2801
- Planning opportunities before expatriation, including gifting and wealth-transfer strategies
Learning Objectives
After completing this course, you will be able to:
- Identify the three covered expatriate tests under IRC Section 877
- Determine the federal income tax consequences of the mark-to-market exit tax
- Ascertain the scope and mechanics of IRC Section 2801, including the January 2025 final regulations and Form 708 filing obligations
- Recognize pre-expatriation planning opportunities, including strategic use of the OBBBA's permanent $15 million estate and gift tax exemption
- 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/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, 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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
