Pre-Immigration Tax Planning

This CLE program provides tax attorneys with a practical guide to planning tools and techniques for clients who are nonresident aliens contemplating residency/citizenship changes rendering them United States taxpayers. Seasoned international taxation attorney Patrick J. McCormick discusses the differences in tax scope between nonresident aliens and United States taxpayers, both for income tax and estate/gift tax purposes. This course also details strategies for minimizing income and transfer tax post-residency, including basic strategies for non-U.S. situs assets, structuring "drop-off" trusts, and planning for the possibility of the nonresident alien's return to their country of origin.

Learning Objectives:

1. Identify the differences in tax scope between nonresident aliens and the United States individuals

2. Review the differences in estate and gift tax exposures between noncitizen non-domiciled individuals and the United States individuals

3. Explore strategies for minimizing income and transfer tax post-residency