Pre-Immigration Tax and U.S. Investment Planning for High Net Worth Individuals
Navigating the EB-5 Investor's Visa Program, Leveraging Tax Credits and Avoiding Tax Traps
Recording of a 90-minute CLE/CPE webinar with Q&A
Conducted on Tuesday, April 26, 2016
Recorded event now available
This CLE/CPE webinar will provide tax counsel and advisers with a comprehensive guide to the tax and investment planning challenges and opportunities for high net worth foreign clients seeking to immigrate to the United States. The panel will discuss strategies for minimizing the U.S. tax impact of foreign-source ordinary and capital income prior to establishing tax residency in the U.S., and will also detail the EB-5 program for nonresidents seeking to establish permanent residency through investment in the U.S. economy and the tax issues that can arise from participating in a regional center.
The United States is increasingly becoming a tax haven for high net worth foreign individuals, even as we see U.S. corporations invert to lower-tax destinations. The U.S. resistance to additional banking disclosure rules is reinforcing America’s image as the ultimate destination point for many wealthy immigrants. This creates an opportunity for tax counsel and advisers to provide critical income and transfer tax planning to minimize the U.S. tax impact of preexisting foreign assets, and to help design an immigration strategy through investment in the U.S.
Because the U.S. imposes tax on its residents’ worldwide income, a key consideration in preserving the financial wealth of would-be immigrants to the U.S. is whether to accelerate income and gains, and defer deductions/losses prior to establishing U.S. residency. In most cases, this is a desirable strategy, particularly if the U.S. statutory tax rate is higher than the immigrant’s current tax home, but tax counsel must be aware of the impact of this plan on after-tax holdings.
Another important aspect of pre-immigration planning is assisting clients in establishing U.S. residency and gaining immigration priority through applying for an EB-5 Investor Visa. This requires making a substantial investment in a U.S. trade or business in which the immigrant would take an active role. Tax advisers need to thoroughly understand the requirements of this program to assist clients in the application process.
Listen as our experienced panel provides a thorough guide to the nuances of pre-immigration tax planning, offering practical tips to help assist high net worth clients transition into the U.S. in a tax-efficient manner.
- Residency and tax consequences
- Pre-immigration planning goals
- Avoiding anti-deferral rules
- Minimizing transfer tax impact
- EB-5 visa program and tax considerations
- EB-5 and New Markets Tax Credits
- Covered expatriates and the “eight-year rule”
The panel will review these and other important issues:
- What are the key considerations in wealth preservation prior to 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
- How does the “eight-year” rule operate for covered expatriates?
After completing this course, you will be able to identify the critical tax issues involved in pre-immigration tax planning. You will know how to evaluate when to accelerate income and gains, and how to design an asset transfer strategy to minimize U.S. taxation on preexisting foreign-based assets. You will also have a thorough understanding of the EB-5 investor visa program, and will be able to navigate the application process through the program’s regional centers.
Larry J. Behar, Esq., Managing Partner
Behar Law Group,
Ft. Lauderdale, Fla.
Mr. Behar specializes in solving complex immigration issues generating business immigration solutions when representing entrepreneurs, investors, multinational companies, professionals and completes family reunification. He published two books in multiple languages, How to Immigrate to U.S.A. and EB-5 United States Immigration through Investment.
Richard S. Lehman, Atty
United States Taxation and Immigration Law,
Boca Raton, Fla.
Mr. Lehman's tax law practice focuses on an array of commercial transactions involving an international and domestic client base. He previously served as Senior Attorney, Interpretative Division, Chief Counsel’s Office, Internal Revenue Service, Washington D.C. He authored articles on taxation and was editor and contributing author of A Guide to Florida International Business and Investment Opportunities.
CLE On-Demand - Streaming Video
Note: Self-study CPE and EA credits are not offered on this On-Demand webinar.
Includes recorded streaming video of full program plus PDF handouts.
On-demand is the only recorded format recognized for CLE credits in DE, IN, KS, LA, MS, NC, OH, OK, SC, TN, VA, WI.
AK, AZ, CA, CO, CT, DE, FL, GA, HI, IA, ID, IL, IN*, KS, KY, LA, ME, MN, MO, MT, NC, ND, NH**, NJ, NM, NV, NY, OH*, OK, OR, PA, SC, TN, TX, UT, VA, VT, WA, WI, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
*Only available for attorneys admitted for more than two years. For OH CLE credits, only programs recorded within the current calendar year are eligible - contact the CLE department for verification.
**NH attendees must self-determine if a program is eligible for credit and self-report their attendance.
CLE On-Demand Video $297.00
Includes full event recording plus handouts.
Note: Self-study CPE and EA credits are not offered on recorded events.
Strafford is an approved provider and self-study CLE credit is available in most states.
AK, AZ, CA, CO, CT, FL, GA, HI, IA, ID, IL, KY, ME, MN, MO, MT, ND, NJ, NM, NY, OR, PA, TN, TX, UT, VT, WA, WV, WY (Note: Some states restrict CLE eligibility based on the age of a program. Refer to our state CLE Map for additional information.)
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Tax Law Advisory Board
Steptoe & Johnson
Morrison & Foerster
Partner and Practice Group Leader - Tax
Waller Lansden Dortch & Davis
Holland & Knight
Partner, Cross-Border Transactions Tax
Fraser Milner Casgrain
Federal Tax Partner
Partner, Tax-Exempt Organizations
Steptoe & Johnson
Partner, Corporate Tax and Due Diligence
Ivins, Phillips & Barker
Managing Director, State and Local Tax Practice
Partner & Co-Chair, State & Local Tax Practice
Sutherland Asbill & Brennan
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