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Pre-Immigration Income Tax Strategies and Nuances for First Year Tax Filing

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, September 28, 2021

Recorded event now available

or call 1-800-926-7926

This course will explain tax strategies, caveats, and considerations for nonresidents to reside in the U.S. or become U.S citizens. Our panel of foreign tax experts will discuss specific strategies, including basis step-up options, drop-off trusts, income acceleration, manipulating tax rates, and other techniques focusing on reducing overall income and transfer taxes paid by current nonresident aliens.


There are numerous tax considerations for a nonresident alien considering becoming a U.S. taxpayer. There is also a window of opportunity for future U.S. residents to take advantage of jurisdictional tax rates. For certain income items not otherwise subject to U.S. taxation, a future taxpayer may want to accelerate income recognition and pay tax on the item before residency.

The current estate tax exemption for foreigners is minuscule compared to the exemption available to residents. Since there is no basis step-up upon commencement of citizenship and no credit given for any exit taxes paid to a prior home country, pre-immigrants should consider strategies to step-up basis in appreciated assets before becoming residents. At the same time, imminent U.S. tax changes add another layer of complexity and necessity to tax planning for future U.S. residents and citizens. International tax advisers working with nonresident aliens need to understand the options available to significantly reduce both income tax and estate and gift taxes for these individuals.

Listen as our authoritative panel of international tax experts explains methods available to reduce overall tax liability for nonresident aliens looking to reside in the United States.



  1. Pre-immigration considerations
  2. U.S. income tax regime
  3. U.S. estate and gift tax
  4. Planning strategies
    1. Basis step-up options
    2. Income acceleration
    3. Drop-off trusts
    4. Other planning strategies
  5. Impending legislation affecting immigration strategies


The panel will cover these and other critical issues:

  • Making transfers to drop-off trusts to reduce taxation
  • Removing income from the U.S. tax scope to eliminate future taxation
  • Sale and reacquisition strategies to obtain basis step-up
  • The effect of potential legislation on pre-immigration tax strategies
  • What are the tax filing options available in the first year of filing


McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.

Culhane Meadows Haughian & Walsh

Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting...  |  Read More

Touriel, Asher
Asher Touriel, CPA, EA

Touriel US Tax Advisory

Mr. Touriel from Touriel US Tax Advisory LTD is a Certified Public Accountant (Israel) and an Enrolled Agent in...  |  Read More

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