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 course will provide attendees with a comprehensive look at Section 877A, as well as strategies for minimizing the impact of expatriation taxes. The panelist 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 panelist will review these and other compelling issues:
- Who is impacted 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
K. Eli Akhavan
Norton Rose Fulbright US
Mr. Akhavan focuses his practice on domestic and international estate, asset protection and tax planning for high... | Read More
Mr. Akhavan focuses his practice on domestic and international estate, asset protection and tax planning for high net-worth individuals and their families. His clients include executives, real estate owners and professionals, nursing home operators, professional athletes, entrepreneurs, owners of closely-held businesses and hedge fund and private equity professionals. Additionally, Mr. Akhavan represents family offices in their tax, estate and business succession planning needs. He is a is a widely published author and frequent speaker on estate planning issues.Close