Navigating International Domicile Changes: Residency Issues, Exit Tax, and Green Card Revocations

The last few years have seen a marked increase in domicile/residency changes by high-net-worth individuals--particularly at the international level. Additionally, there is marked increase in the U.S. citizens and green card holders seeking to renounce their citizenship or US green card. An international domicile or residency change can be undertaken by an individual for many reasons - retirement, political reasons, return to the home country, or employment-related. Whatever be the reason, a thorough understanding of the effect of a move/change on an individual’s global tax position should be thoroughly reviewed.

Listen as Ragini Subramanian, Senior Manager, International, Private Client Services at Eisner Advisory Group, explains essential factors for taxpayers and advisers to consider for international residency changes while taking into account country examples where possible. The presenter will also provide a comprehensive review of Impact of green card/ US citizenship revocations.

1. Country specific residency rules
2. Worldwide versus territorial system of taxation across various jurisdictions
3. Country tax rates and impact on overall tax position
4. Special rules associated with real property holdings
5. Holding structure for various investments
6. Foreign tax credit planning
7. Residency starting and ending dates in the new jurisdictions and in the US
8. Estate and gift tax impact of domicile change
9. Pre-domicile change planning examples
10. Exit tax under section 877A

The panelist will review these and other critical issues:

• What may be a US tax impact of a given holding structure for foreign investments
• How the treaty tie-breaker rules are used to determine domicile
• Critical length of stay considerations for residency
• What are the necessary steps to revoke green card status?

Learning Objectives

After completing this course, you will be able to:

• Identify tax considerations for international domicile change
• Differences and similarities between tax issues in the US and selected foreign jurisdictions
• Visa considerations for international domicile change
• Tax implications of expatriation and considerations before and after expatriation

• 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.

IRS Approved Provider

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