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.
United States Tax Considerations For Nonresident Taxpayers Series – Inbound
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
United States Tax Considerations for Multinational Activities – Outbound
Course Objectives
Individual Tax Considerations
- Learn how individuals are classified as United States tax residents for income tax purposes, and reclassification provisions available
- Analyze the classification rules for individuals in the context of estate and gift taxes, and evaluate their implications for tax planning and compliance
- Understand how individuals minimize double taxation on foreign-sourced income
GILTI and FDII: Structuring Multinational Businesses
- Learn how foreign entities are classified for U.S. tax purposes
- Learn how to determine whether a foreign corporation is a controlled foreign corporation subject to GILTI/Subpart F rules
- Understand how GILTI and Subpart F provisions create current inclusions for U.S. shareholder
- Recognize the potential benefits of U.S. incorporation for foreign activities based on the FDII deduction
- Understand how to determine the best option for structuring foreign activities
International Tax: Foreign Trusts for U.S. Taxpayers
- Learn how trust structures are classified for United States tax purposes
- Learn special United States income tax rules applicable to foreign nongrantor trust structures
- Understand how foreign retirement assets and classified and taxed for United States purposes
Reporting Foreign Accounts and Assets
- Learn how foreign accounts are reported for FBAR purposes
- Obtain up-to-date information on FBAR case law
- Understand how FBAR penalties are assessed and collected
- Ascertain how foreign interests are reported for Title 26 purposes
- Obtain up-to-date information on Title 26 foreign information reporting case law
International Tax: PFICs
- Know how to determine whether a foreign entity is a passive foreign investment company
- Understand the default rules for PFIC taxation and elections available to alter the same (QEF and MTM elections)
- Learn how PFIC interests are reported for tax return purposes
Retroactive Relief Options for International Tax Compliance Errors
- Understand how foreign-sourced income is reported on United States returns and how foreign assets are reported for information purposes
- Learn in detail how submissions are made under the Streamlined Filing Procedures, and general considerations for a submission/qualification
- Learn in detail how submissions are made under the Delinquent FBAR/International Information Return Submission Procedures, and general considerations for a submission/qualification
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
