International Tax in Practice: Advising Clients on Tariffs, Tax Treaties, and Cross-Border Strategy

This program equips attorneys with the practical skills necessary to advise clients navigating the complex intersection of U.S. tax rules and global tariffs. With a focus on real-world advisory strategy, participants will learn how to identify and apply key concepts such as effectively connected income (ECI), FDAP income, and tax treaty benefits to nonresident clients operating across borders. The course also covers how to evaluate transfer tax exposure for foreign individuals and proactively structure transactions and ownership to mitigate risk. Through a detailed look at legal frameworks and practical planning techniques, attorneys will gain actionable skills to support clients in cross-border compliance, entity structuring, and risk management in an era of heightened trade tensions and regulatory complexity.

Learning Objectives:

1. Apply U.S. tax rules to real-world scenarios involving nonresident clients, including how to classify and address ECI and FDAP income

2. Analyze client facts to determine whether treaty benefits may reduce or eliminate withholding obligations

3. Develop advisory strategies for mitigating estate and gift tax exposure for nonresident individuals with U.S.-based assets

4. Assess when tariffs and tax rules create overlapping obligations, and structure cross-border transactions accordingly

5. Translate complex international tax and tariff principles into client-ready guidance, planning considerations, and risk alerts