Nonresident Tax Issues: ECI, Structures for Holding U.S. Assets, Treaty Benefits, Estate and Gift Taxes
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This course will provide tax practitioners working with U.S. nonresident aliens (NRAs) with practical steps to minimize U.S. taxes for these U.S. taxpayers. The panelists will cover the rules for federal income, estate, and gift taxation of nonresidents and provide concrete advice on mitigating these taxes.
Outline
- Nonresident classification
- Income tax default rules
- Income tax treaty modifications
- Estate and gift tax
- Foreign entity taxation
- Considerations for U.S. investments
- Other considerations
Benefits
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?
Faculty

Patrick J. McCormick, J.D., LL.M.
Founder/Managing Partner
McCormick Tax
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.
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Christine Sielicki, EA
Tax Manager
Plante Moran
Ms. Sielicki is a manager within the Global Mobility team. She has over 15 years of experience in personal taxation and... | Read More
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.
CloseEarly Discount (through 06/09/23)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event.
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NASBA details.
Cannot Attend July 6?
Early Discount (through 06/09/23)
CPE credit is not available on downloads.
CPE On-Demand