Pre-Immigration Tax and U.S. Investment Planning: Foreign-Source Income, Establishing Tax Residency, EB-5, and More
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a comprehensive guide to pre-immigration tax and investment planning challenges and opportunities under current tax law. The panel will discuss strategies for minimizing the U.S. tax impact of foreign-source ordinary and capital income before establishing tax residency in the U.S., detail the current EB-5 program for nonresidents seeking to establish permanent residency through investment in the U.S. economy, and review tax planning opportunities in structuring U.S. investments.
Outline
- Residency and tax consequences
- Pre-immigration planning goals
- Avoiding anti-deferral rules
- Minimizing transfer tax impact
- Structuring U.S. investments: key tax considerations, EB-5 and other options
Benefits
The panel will review these and other essential issues:
- What are the crucial considerations in wealth preservation for a foreign individual becoming a U.S. resident for tax purposes?
- How to avoid anti-deferral rules in pre-immigration transactions
- How to navigate the EB-5 program through a regional center
- What are the various tax consequences of a foreign person investing in the U.S.?
Faculty
Jennifer Migliori
Partner
Duane Morris
Ms. Migliori is a partner in Duane Morris' Corporate Practice Group and practices in the areas of... | Read More
Ms. Migliori is a partner in Duane Morris' Corporate Practice Group and practices in the areas of international taxation, wealth preservation planning and private equity transactions. She has experience developing and implementing tax-efficient investment structures. Ms. Migliori has developed a focus on complex international corporate structures, trust planning, and compliance. She also regularly advises clients on various tax matters including international information sharing arrangements, tax treaties, the Foreign Account Tax Compliance Act (FATCA), expatriation, pre-immigration tax planning, and tax controversy matters including audit representation and voluntary disclosures. Ms. Migliori is vice-chair of the firm’s Private Equity Division within the Corporate Practice Group. She represents investors, fund managers, family offices, financial institutions, fiduciaries, high-net-worth individuals and owners of closely-held companies. Ms. Migliori is admitted to practice law in Florida and Pennsylvania, and before the U.S. Tax Court. Ms. Migliori earned her LL.M. in Taxation from the New York University School of Law and her law degree from University of Virginia School of Law, where she was Editor-in-Chief of the Virginia Tax Review. She is a graduate of the Florida Fellows Institute of the American College of Trust and Estate Counsel (ACTEC).
Close
Connor J. Southwell
Partner
Citrin Cooperman Advisors
Mr. Southwell is a partner in the firm's International Taxation Services Practice. He has over a decade of... | Read More
Mr. Southwell is a partner in the firm's International Taxation Services Practice. He has over a decade of experience advising high net worth individuals and closely held businesses in international tax planning and compliance. Mr. Southwell works with both U.S. nationals and business entities with activities in foreign jurisdictions, and nonresidential individuals and companies that seek to establish a presence and economic nexus to the U.S. His specialties include the subpart F and GILTI regimes, foreign tax credit planning, FATCA compliance, and the analysis and application of U.S. and OECD model income tax treaties.
Close