BarbriSFCourseDetails
  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Nonresident Tax Issues: ECI, Structures for Holding U.S. Assets, Treaty Benefits, Estate and Gift Taxes

$197.00

This course is $0 with these passes:

CPE
ALL
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Description

NRAs are taxed on income effectively connected with a U.S. trade or business and non-U.S. trade or business income that is sourced to the U.S.--fixed and determinable annual or periodic income, better known as FDAP income. With more and more NRAs doing business in the U.S., the determination of whether a regular, substantial, and continuous business activity is taking place within the U.S. is critical.

The primary criteria for taxation, however, can be altered when and if there is a U.S. treaty with the related country. Deductions and credits are available to offset business income too, but a return must be timely filed to take advantage of these.

In addition to income taxes, NRA advisers must consider the significant effect of estate and gift (transfer) taxes when advising NRAs. The U.S. estate tax regime is particularly potent since NRAs receive a $60,000 estate tax exclusion compared to the resident exemption of $12.92 million (2023).

A nonresident estate tax is assessed on all U.S. property owned at death with certain exceptions. Like income tax, estate and gift taxation can be modified by U.S. treaties. Understanding the estate as well as income tax issues affecting nonresidents is vital for practitioners working with these U.S. taxpayers.

Listen as our panel of experts explains the ins and outs of NRA taxation, including nonresident classification, foreign entity taxation and ownership structures, U.S. investments by NRAs, and potential tax repercussions faced by these U.S. taxpayers.

Presented By

Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Christine Sielicki
Senior Manager, Global Mobility Tax
Plante Moran

Ms. Sielicki is a manager within the Global Mobility team. She has over 15 years of experience in personal taxation and has spent the last 10 years specializing in Global Mobility. Ms. Sielicki assists clients during the entire life cycle of a foreign assignment. She deals with employer and employee compliance in relation to both inbound and outbound international employment. Ms. Sielicki has significant experience managing tax return programs, international payrolls, analysis of overseas benefits, advising on residence and domicile matters and providing consulting advice, both pre– and post- assignment. 

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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).

Date + Time

  • event

    Thursday, July 6, 2023

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Nonresident classification
  2. Income tax default rules
  3. Income tax treaty modifications
  4. Estate and gift tax
  5. Foreign entity taxation
  6. Considerations for U.S. investments
  7. Other considerations

The panel will review these and other critical issues:

  • How is effectively connected income determined?
  • What is FDAP income and how is it taxed?
  • What common treaty benefits are available to lower income, estate, and gift taxes for NRAs?
  • How does asset type influence holding structure choices?
  • When should an NRA file a protective income tax return?

Learning Objectives

After completing this course, you will be able to:

  • Identify FDAP income
  • Ascertain when treaty provisions may trump income and transfer tax rules
  • Determine when income may be effectively connected with the U.S.
  • Decide appropriate holding structures for U.S. assets
  • 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 pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

BARBRI 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

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 Strafford-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 .