U.S.-Australia Tax Issues for Dual Status Taxpayers: Tax Planning and Compliance Requirements, Treaty Operations
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide estate planners with a comprehensive guide to tax planning challenges and opportunities for clients who have a tax presence in both the U.S. and Australia. The panel will discuss the U.S. tax law and treaty provisions that govern tax and fiduciary rules in both Australia and the United States. The webinar will focus on the U.S. tax and other consequences for Australian clients with a U.S. tax presence and U.S. taxpayers with Australian-based pensions and other assets.
Outline
- The U.S.-Australia income tax treaty overview and dual tax mitigation provisions
- Domicile and residency rules
- Passive and unearned income treatment
- U.S. tax reporting requirements of Australia-sourced investments
- U.S. tax of Australian Superannuation funds
Benefits
The panel will review these and other important topics:
- What are the tax treaty provisions for mitigating dual taxation on ownership of cross-border pass-through entities?
- Limitation of benefits clauses and provisions in the U.S.-Australia income tax treaty
- U.S. tax treatment of Australian Superannuation funds
- Key risks and challenges of passive/unearned income in cross-border situations
- U.S. reporting requirements of Australia-sourced investments
Faculty
Patrick J. McCormick, J.D., LL.M.
Founder/Managing Partner
McCormick Tax
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.
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Daniel N. Price
Attorney
Law Offices of Daniel N.Price
Mr. Price's legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax... | Read More
Mr. Price's legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Mr. Price served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Mr. Price has had unique experience with tax controversy and tax administration.
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