Nonresident Tax Issues: Effectively Connected Income, Structures for Holding U.S. Assets, Treaty Benefits
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax practitioners working with U.S. nonresident aliens (NRAs) 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
- COVID-19 implications
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

Tracy Green Landauer
Partner
Culhane Meadows Haughian & Walsh
Ms. Landauer is a partner in the firm’s New York office where she focuses her practice on Tax and Trusts &... | Read More
Ms. Landauer is a partner in the firm’s New York office where she focuses her practice on Tax and Trusts & Estates counsel. She provides personal estate planning, charitable gift planning and closely-held business succession planning to a broad range of domestic and international individuals and families. Ms. Landauer also provides ongoing and special issue representation to both new and established private foundations (individual and corporate) and public charities including arts, health, educational, community, literary, research and trade organizations.
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Patrick J. McCormick, J.D., LL.M.
Partner
Culhane Meadows Haughian & Walsh
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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