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Live Webinar

90-minute live streaming program
  • August 19
  • 1:00 - 2:30 pm EST

Estate Planning Considerations for Dual Residents

August 19

Gain an understanding on the key concepts you should be considering when estate planning for a dual resident client including tax issues and will options.

In an increasingly global society, the world is shrinking and clients are becoming more mobile. Just last year, over one million foreign nationals obtained green cards. U.S. professionals move overseas for better job opportunities, and disgruntled U.S. taxpayers renounce their U.S. citizenship at an unprecedented rate. Currently, there are an estimated nine million U.S. expatriates living abroad. During the first three months of 2020, more U.S. citizens sought to renounce their U.S. citizenship than during the entirety of 2019. Often, these mobile clients are unaware that they have dual status and become or remain subject to certain U.S. tax obligations. Even those clients who are aware of their dual residency frequently fail to comply with their U.S. tax obligations and end up facing substantial costs associated with their noncompliance. Moreover, estate planning for such mobile clients is important, if not essential. The problem, however, is the complexity of the U.S. tax rules involving international clients. These rules frequently change, and the challenge for domestic advisors is exacerbated by a contrasting variety of rules and legal regimes of the countries in which such clients or their assets are located. Thus, there is an increasing demand for domestic advisors who have the ability to identify dual resident clients, to be aware of such clients’ U.S. tax obligations, and to design estate plans that factor in all potential issues and that will survive across the border. This topic is intended to serve as guidance for both domestic advisors and dual resident individuals. It will cover the intricacies of the dual residency rules and a number of key non-tax and tax factors that must be considered when advising dual resident clients and when designing tax-efficient and viable estate plans. This information is also intended to help determine whether a dual resident client is in compliance with applicable U.S. tax obligations.

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Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Determination of Dual Residency Status
  • Dual Residency Overview
  • Income Tax Residency
    • Green Card Test
    • Substantial Presence Test
    • Dual Status Taxpayer
    • Treaty Tie-Breaker Exception
  • Transfer Tax Residency Equals Domicile
    • No Precise Definition of Domicile
    • Subjective Facts and Circumstances Test
    • Transfer Tax Treaty Resident
Initial Estate Planning Considerations for Dual Residents
  • Main Legal Systems of the World
    • Overview
    • Property Located in Another Country
    • Forced Heirship and Other Default Restrictions
  • Determination of Governing Law
  • Will Options
    • Recognition of U.S. Wills
    • U.S. Will
    • Situs Will
    • International Will
  • Recognition of U.S. Trusts
Transfer Tax Considerations for Dual Residents
  • Overview
  • Estate Tax Considerations
    • General Rules
    • Situs Rules
    • Surviving Non-U.S. Citizen Spouse; QDOT
  • Gift Tax Considerations
    • General Rules
    • Gifts From Dual Residents to NRAs
    • Gifts From NRAs to Dual Residents; Situs Rules
    • Non-U.S. Citizen Spouse
  • Transfer Tax Treaties
The Expatriation Regime
  • Overview
  • Definitions
  • The Exit Tax
  • The 2801 Tax
Income Tax Considerations for Dual Residents
  • General Rules
    • Foreign Tax Credit
    • Foreign Earned Income Exclusion
  • Income Tax Treaties
  • Community Property Considerations
  • Income Tax Matters Concerning Foreign Assets
    • Foreign Trusts
    • Controlled Foreign Corporations (CFCs)
    • Passive Foreign Investment Companies (PFICs)
    • Transfers of Appreciated Property to Foreign Entities
  • Selected Reporting Requirements
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

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  • AL CLE 1.5
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.5 hours credit.
     
  • AR CLE 1.5
     
  • This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • NH MCLE 1.5
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 90 Minutes.
     
  • NJ CLE 1.8
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.8 hours of total CLE credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • NY CLE 1.5 including Areas of Professional Practice 1.5
     
  • This course has been approved in accordance with the requirements of the New York Continuing Legal Education Board for up to a maximum of 1.5 credit hours in the area(s) of Areas of Professional Practice for 1.50 hours. Each hour may be counted only as satisfying one category of credit. Duplicate credit for the same hour of instruction is not permitted. This course qualifies for both established and newly admitted attorneys. Lorman Business Center, LLC. has a financial hardship guideline. Please contact customer service at 1.866.352.9539 for instructions on how to apply.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of CLE credit.
     
  • WA CLE 1.5
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.5 hours of Law & Legal Procedure credit.
     
  • WI CLE 1.5
     
  • This program has been approved by the Board of Bar Examiners for 1.5 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.8
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
     
  • Enrolled Agents 1.0
     
  • This program qualifies for 1.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     
  • CPE 1.8 including Specialized Knowledge 1.8
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 1.8 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Specialized Knowledge for 1.8 hours. Prerequisite: . Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, LLC. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Specialized Knowledge and Applications for 1.5 hours.
     

Who should attend?

This live webinar is designed for attorneys, estate planners, accountants, CFOs, controllers, business owners and managers, tax managers, financial planners and enrolled agents.

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Anthony F. Vitiello, Esq.

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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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 407149
Published 2020
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