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 premium 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. The panel will discuss the impact of new tax law on expatriation planning techniques, critical challenges under Section 877A and guidance on exiting the U.S. tax regime.
- Who is a covered expatriate?
- The three 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
- Planning techniques
The panel will review these and other compelling 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
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
Philip D. W. Hodgen
Mr. Hodgen specializes in the international tax arena. He counsels clients on international tax issues arising when... | Read More
Mr. Hodgen specializes in the international tax arena. He counsels clients on international tax issues arising when clients deal with multiple tax systems, tax planning, cross-border businesses and investments. He frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, and other professional groups.Close