Gain
a better understanding of the impact of new tax law on expatriation,
issues under section 877A and following the US Tax regime.
For a variety of reasons, individuals may consider expatriating from the United States. Often, however, they fail to consider the potential income, estate and inheritance tax consequences of expatriation.
Without careful consideration and proper planning, individuals may unintendedly subject themselves to the punitive exit tax or a continuing U.S. tax liability if the appropriate forms are not properly filed. This topic helps practitioners understand the mechanisms relating to tax expatriation from the United States.
Through an understanding of the net income and net wealth test, a client can be properly advised as to the tax impact of their decision to leave the United States. Additionally, proactive planning can assure an individual properly expatriates and minimizes exposure to the exit tax.
Learning Objectives:
- You will be able to recognize who is a covered expatriate.
- You will be able to describe the income tax consequences of being a covered expatriate.
- You will be able to discuss the estate tax consequences of being a covered expatriate.
- You will be able to identify certain planning techniques to avoid classification as a covered expatriate.
Who Is an Expatriate?
·
Are
You a Covered Expatriate?
·
Net
Income Test
·
Net
Worth Test
Tax Consequences
·
Income Tax
·
Estate Tax
·
Inheritance Tax
Planning and Other
Considerations
·
Avoiding Classification as a Covered Expatriate
·
Exceptions
·
How
to Expatriate
Credit Information (Sponsored by Lorman Education Services):
- CLE
- CPE
- AIPB
- NASBA
For Detailed Credit Information page
click here
Only registered attendee will receive continuing education credit.
Faculty
Datan Dorot, Dorot & Bensimon PL
- Managing partner of Dorot & Bensimon PL
- Legal background encompasses a wide range of estate planning, business planning, and taxation law, primarily focused on international issues
- Written many articles including “New IRS Insight on Taxation of Foreign Hedge Fund Loans: What Does it Really Mean to the Foreign Hedge Fund Manager”, Florida Bar News Tax Bulletin, Fall, 2009; “So the Sun Set, Now What? 2010 Estate and GST Tax Repeal”, Florida Bar News Tax Bulletin, Winter, 2010; “Voluntary Disclosure Program Dust yet to Settle: From Beginning to Where?” publication forthcoming; “Expatriation and the Mark-to-Market Madness: The Impact of Notice 2009-85”, publication forthcoming; “Offshore Account Compliance: The Evolution of a Revolution”, Florida Bar Journal, December 2014; “Advising Holders of Offshore Financial Accounts: FBAR, Voluntary Disclosure, and New Legislation”, National CLE Teleconference, Lorman Educational Success, April 16, 2010
- Spoke on “IRS Disclosure Requirements for Uncertain Tax Positions”, Ullman Year In Review, Tax Section of the Florida Bar Annual Meeting, Amelia Island, July 4, 2010; “Vegas is not just for gamblers: The benefits and opportunities of Nevada discretionary trusts for NRA’s", TTN Conference Sao Paulo, November 2017; “Vegas is not just for gamblers: The benefits and opportunities of Nevada discretionary trusts for NRA’s”, TTN Conference Bueno Aires, December 2017
- Member Tax Section of the Florida Bar, Real Property, Probate and Trust Law Section of the Florida Bar, Executive Board Member, Greater Miami Jewish Federation, Director, South Florida Tax Lunch of the New Tax Lawyers for the Tax Section of the Florida Bar, Vice Chair, Estate and Gift Tax in the Federal Tax Division of the Tax Section of the Flor-ida Bar, Vice Chair, Tax Membership Directory of the Tax Section of the Florida Bar and Leadership Miami
- LL.M. degree in estate planning, University of Miami School of Law; J.D. degree, University of Florida; B.S. degree in international business, Florida Atlantic University; B.S. degree in marketing management and a minor in Spanish, Florida Atlantic University
- Can be contacted at 305-921-9421 or ddorot@dorotbensimon.com
Dustin Sher, Dorot & Bensimon PL
- Associate attorney at the office of Dorot & Bensimon PL
- With a strong accounting background from his experience in the International Tax group at an accounting firm, he adds a valuable perspective to addressing clients’ needs
- His practice includes pre-immigration tax planning, structuring for foreign investment in U.S. real property, FATCA compliance for clients with U.S. filing obligations and planning for U.S. individuals making investing abroad
- Member Tax Section of the Florida Bar, Young Lawyers Division of the Florida Bar
- LL.M. degree in taxation, University of Miami School of Law; certificate in international taxation, University of Miami School of Law; J.D. degree, American University, Washington College of Law; Master of accountancy degree, George Washington University; B.A. degree in U.S. history, Vanderbilt; B.A. degree in economics, Vanderbilt
- Can be contacted at 305-921-9421 or dsher@dorotbensimon.com
(Not available outside the US)