Demonstrate your competency and increase your or your firms earning power by taking and passing the Lambers United States Tax Considerations for Nonresident Taxpayers.
Until now, training options for international tax specialization have been limited, despite demand vastly exceeding supply for decades. The need for specialized knowledge to appropriately advise clients in the multinational tax content combined with the limited options to obtain/market that knowledge has created enormous opportunity for those with the requisite knowledge to develop a lucrative, expansive, and sought-out practice. Those opportunities are particularly noteworthy among American nonresidents – those without existing United States advisors who often require broad advice from an American service professional.
Lambers has teamed with Patrick J. McCormick, J.D., LL.M., one of the United States’ pre-eminent international tax authorities, to create a fourteen-hour certificate course series titled United States Tax Considerations for Nonresident Taxpayers. This series will feature 10 different courses and will qualify you for up to 14 hours of either IRS CE or NASBA CPE credit.
Courses included are:
- Classification of Nonresident Entities (2 Hours)
- Tax Classification of Individuals (1 Hour)
- Transfer Taxes for American Nondomiciliaries (2 Hours)
- Compliance Requirements for Nonresidents (1 Hour)
- Foreign Investment in United States Real Property (1 Hour)
- Income Tax Inclusions for Nonresidents: Statutory Rules (1 Hour)
- Income Tax Inclusions for Nonresidents: Tax Treaty Modifications (2 Hours)
- Income Sourcing Rules (2 Hours)
- Nonresident Taxation: Introduction to Considerations (1 Hour)
- Nonresident Taxation Planning Opportunities and Practice Considerations (1 Hour)
VIEW OBJECTIVES
United States Tax Considerations for Nonresident Taxpayers Series
Course Objectives
Classification of Nonresident Entities
- Threshold Considerations
- Is the Entity a Trust?
- Foreign Business Entities
- Foreign Business Entities – Entity Classification
- Foreign Business Entities – Elections
- Foreign Business Entities – Relevance Determinations
- Taxation of Foreign Business Entities
- Foreign Corporations – Subpart F Income
- Foreign Corporations – GILTI
- GILTI – Regulatory Guidance
- Foreign Corporations – Passive Foreign Investment Companies
Tax Classification of Individuals
- Income Tax Classification
- Taxpayer Classification
- Special Options for Nonresident U.S. Taxpayers
- Foreign Tax Credit
- Foreign Earned Income Exclusion
- Expatriation
- United States Transfer Tax Classification
Transfer Taxes for American Nondomiciliaries
- Background Considerations
- Initial Considerations – Taxpayer Classification
- Taxpayer Classification
- United States Transfer Taxes – Classification
- Nonresident Individuals – Transfer Taxes
- Foreign Trusts
- Planning Mechanics
Compliance Requirements for Nonresidents
- Background Considerations
- Income Tax Reporting
- Information Filing Obligations
- Form 8832
- Form 8833
- Form 1042
- Form 1042-S
- Form W-8ECI
- Forms W-8BEN/W-8BEN-E
- Form 5472
- Corporate Transparency Act
Foreign Investment in United States Real Property
- Effectively Connected Income
- FDAP Income
- Nonresidents – ECI vs. FDAP Income
- Effectively Connected Income
- Nonresidents – Net Election to Treat Real Property Income as ECI
- Foreign Investment in United States Real Property (“FIRPTA”)
- Nonresidents – FIRPTA
- FIRPTA – Withholding Obligations
- Nonresident Individuals – Transfer Taxes
- Structuring Nonresident United States Real Estate Investments
Income Tax Inclusions for Nonresidents: Statutory Rules
- Background Considerations
- Effectively Connected Income
- Foreign Corporations – Branch Profits Tax
- FDAP Income
- Withholding Requirements
- Nonresident Tax in a Digital Economy
Income Tax Inclusions for Nonresidents: Tax Treaty Modifications
- Income Tax Treaties – Basic Structure
- Income Tax Treaties – Who Can Obtain Benefits?
- Tax Treaties – Common Provisions
- Permanent Establishments
- Permanent Establishment Mechanics
- Permanent Establishments in a Digital Economy
- Tax Treaties – FDAP Income
- FDAP Income Modification Examples
- Reporting Requirements
Income Sourcing Rules
- Income Sourcing Rules
- Interest
- Dividends
- Personal Services Income
- Multiyear Compensation Arrangements
- Income from Property Use
- Income from Property Disposition
- Other Rules of Note
- Foreign Derived Intangible Income
- Domestic Corporations – FDII
- Foreign Derived Intangible Income
Nonresident Taxation: Introduction to Considerations
- Background Considerations
- Income Tax Treaties – Basic Structure
- Tax Treaties – Common Provisions
- Tax Treaties – FDAP Income
- United States Transfer Taxes – Classification
- Income Tax Reporting
Nonresident Taxation Planning Opportunities and Practice Considerations
- Structuring Nonresident United States Investments
- Structuring Nonresident Investments
- Pre-Immigration Tax Planning
- Expatriation Considerations
Earn your United States Tax Considerations for Nonresident Taxpayers Series-Inbound certificate from Lambers and Patrick McCormick and get ready to help a plethora of clients now.
14 Hour United State Tax Considerations for
Nonresident Taxpayers course Only $999!
The series will be guided through use of hypotheticals/real life examples, with fact patterns presented at the outset of each program and referenced throughout the program to promote active learning.
Upon completion of the course and a short final exam, you will earn a certificate as a “United States International Tax Specialist – Inbound”.
Included with this course, we have created a forum moderated by Patrick in which attendees will be able to ask any and all questions associated with the program
Volume discounts, live in-person group training and live virtual group training for this United States Tax Considerations for Nonresident Taxpayers course is available. For more information contact Kevin Forcier, ktf@lambers.com
