Estate Planning Considerations for Dual Residents
High net-worth individuals and certain long-term green card holders who relinquish their U.S. citizenship or green cards, or so-called covered expatriates, may be subject to an immediate exit tax, an income tax liability under I.R.C. § 877A; and a special transfer tax under I.R.C. § 2801 (the “2801 tax”). This white paper reviews what defines an expatriate and covered expatriate and discusses the exit tax and offers planning points for pre- and post-expatriation gifting.
Agenda
Faculty
Anthony F. Vitiello, Esq.
Connell Foley LLP
- Partner and chairman of the Taxation and Estate Planning Group of Connell Foley LLP (Resident in the Roseland, NJ office)
- Practice is dedicated to sophisticated tax planning for individuals, businesses, estates and trusts, with a particular emphasis on national and multinational estate planning, as well as as-set protection planning
- Lectures extensively and frequently publishes in legal and business journals on a variety of tax and estate planning issues, including those related to federal estate, gift and income tax issues, wealth preservation, trusts, and a multitude of other planning techniques
- Admitted to practice in six states, the District of Columbia and United States Tax Court
- Recognized for the past 10 years in “Best Lawyers in America” in the areas of trust and estates, trust and estates – litigation, and tax litigation and controversy
- LL.M. degree in taxation; J.D. degree, New York University
- Can be contacted at 973-840-2433 or [email protected]
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