Advanced Tax Planning for Nonresident Aliens: Pre-Immigration Strategies
Basis Adjustment Transactions, Drop-Off Trusts, Treatment of Nonresident Investment in the U.S., Resident Alien Exit Planning
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to planning tools and techniques for clients who are nonresident aliens. The panel will go beyond the basics to detail intricate strategies for minimizing income tax, including basis strategies for non-U.S. situs assets, structuring “drop-off” trusts, and planning for the possibility of the nonresident alien’s return to the country of origin.
- Pre-immigration planning for nonresident aliens planning on obtaining resident alien status
- Basis planning
- For current assets located outside the U.S.
- Marketable securities and assets which can be sold and re-purchased before establishing presence in the U.S.
- Transactions and strategies for low-basis assets
- Drop-off trusts and other strategies for high net worth nonresident aliens
- Strategy and treatment of investments by nonresident aliens not contemplating immigration to the U.S.
The panel will discuss these and other relevant topics:
- Pre-immigration basis adjustment strategies for nonresident aliens planning to establish residency in the U.S.
- Creating and funding “drop-off trusts”
- Timing rules for establishing resident alien status
- Treatment of U.S. investments by nonresident aliens
Cindy D. Brittain
Katten Muchin Rosenman
Ms. Brittain is a partner in the firm's Trusts and Estates practice, focusing on domestic and international estate... | Read More
Ms. Brittain is a partner in the firm's Trusts and Estates practice, focusing on domestic and international estate and tax planning. She assists family business members with succession planning and advises her clients on tax mitigation strategies. Ms. Brittain partners closely with clients to design efficient plans that satisfy their goals. She advises on the effective use of multi-state jurisdictions for effective state income tax planning. Ms. Brittain frequently addresses fiduciary and legal issues that arise during trust administration.Close
Thomas M. Giordano-Lascari
Karlin & Peebles
Mr. Giordano-Lascari is an accomplished income tax and transactional attorney specializing in international matters for... | Read More
Mr. Giordano-Lascari is an accomplished income tax and transactional attorney specializing in international matters for high net worth private clients. He is a frequent speaker on sophisticated international tax issues. Mr. Giordano-Lascari is also Chair of the Executive Committee of the Los Angeles County Bar Association Taxation Section.Close
Patrick J. McCormick, J.D., LL.M.
Drucker & Scaccetti
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close