Tax Planning Issues for U.S. Expatriation: Minimizing the IRC 877A Exit Tax
Determining Covered Expatriates, Navigating the Mark-to-Market Tax on Unrealized Gains, Reporting Elections
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes.
- Who is a Covered Expatriate?
- The 3 tests
- The exceptions
- Determining net worth when trust assets are involved
- The taxes applicable to a CE under Section 877A
- The inheritance tax under Section 2801
- Getting below $2M in net worth
The panel will review these and other key issues:
- Who is affected by Section 877A?
- How to calculate the mark-to-market tax on capital gains?
- What types of deferred compensation are subject to the exit tax?
- The effect of the expatriation rules on U.S. gift and estate taxes.
- Strategies for avoiding or minimizing the taxes imposed under Section 877A.
Shannon P. McNulty, J.D., LL.M. (Taxation), CFP®
Law Office of Shannon P. McNulty
Ms. McNulty is an estate planning lawyer in New York City. She works with clients to implement strategies for... | Read More
Ms. McNulty is an estate planning lawyer in New York City. She works with clients to implement strategies for preserving their wealth, protecting their loved ones, and preparing for the eventual transfer of their assets. Shannon regularly counsels clients on the unique tax and estate planning issues that arise in the international context.Close
Michael J. Stegman
Kohnen & Patton
Mr. Stegman's particular areas of focus include protecting assets from the claims of descendants’ creditors... | Read More
Mr. Stegman's particular areas of focus include protecting assets from the claims of descendants’ creditors and divorcing spouses, preserving special assets, reducing or eliminating wealth transfer taxes on a multi-generational basis, using asset protection trusts, and advising on the ramifications of the clients' or decendants' dual nationality, marriage to a foreign person, residence abroad, and holding of foreign assets. He regularly represents nationals who reside in the U.S. or who have investment property here. He works with professionals in foreign jurisdictions to develop plans that respect both laws. He is familiar with the international treaties that pertain to practice in this area.Close
Ann M. Seller
Kohnen & Patton
Ms. Seller's work focuses primarily in estate planning and probate administration. As part of her practice, she... | Read More
Ms. Seller's work focuses primarily in estate planning and probate administration. As part of her practice, she concentrates on international aspects of estate planning including the creation of wills and trusts for multi-national families, estate and gift tax issues that arise with the ownership of cross border property, and advising clients about the U.S. Expatriation Tax.Close
Flott & Co.
Mr. Flott advises businesses, individuals and non-profits on a wide range of international business and tax... | Read More
Mr. Flott advises businesses, individuals and non-profits on a wide range of international business and tax matters, including U.S. taxation of international business and transportation, of U.S. citizens residing overseas, of foreign estates with U.S. property, and of foreign persons and companies with U.S. income or property. He also assists clients with U.S. regulation of international shipping, trucking, bus and freight forwarding operations. He also focuses on U.S. citizenship issues, including expatriation and associated tax issues, and the special compliance challenges associated with long term non-filing of U.S. tax returns and financial reports by U.S. citizens who reside overseas.Close