About the Course
Introduction
This course will provide tax practitioners working with U.S. nonresident aliens (NRAs) with practical steps to minimize U.S. taxes for these taxpayers. The panelists will cover the rules for federal income, estate, and gift taxation of nonresidents and provide concrete advice on mitigating these taxes.
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 $15 million (2026).
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
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. Mr. McCormick is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.
Ms. Schenck joined Caplin & Drysdale in 2025 after two decades of public service. Most recently she served as the National Fraud Counsel and Senior Level Counsel (Offshore) in the Office of Chief Counsel at the IRS. Ms. Schenck assists corporations, individuals, families, trust companies, and tax professionals with criminal and civil tax enforcement and compliance matters. Specifically, she helps clients navigate compliance issues even before IRS involvement, as well as advising clients on civil examinations, summons and subpoena matters, tax and penalty issues, sensitive audits and fraud cases, criminal tax investigations, and related litigation. Ms. Schenck was elected as a Fellow of the American College of Tax Counsel (ACTC) for her extraordinary professional achievements and her dedication to improving the practice of tax law.
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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).
Date + Time
- event
Monday, June 29, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Nonresident classification
II. Income tax default rules
III. Income tax treaty modifications
IV. Estate and gift tax
V. Foreign entity taxation
VI. Considerations for U.S. investments
VII. 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 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 .
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Available On-Demand
Nonresident Tax Issues: ECI, Structures for Holding U.S. Assets, Treaty Benefits, Estate and Gift Taxes
Monday, June 29, 2026
1:00 PM ET/10:00 AM PT
