Pre-Immigration Tax Planning in the 2018 Landscape: Trends, Developments and Updates
In addition to the tax laws imposed by the national government, each U.S. state has its own tax laws on residents subject to its jurisdiction, thus creating a complex tax system. Because of this, foreign nationals and entities seeking to immigrate in the U.S. must first engage in pre-immigration tax planning to minimize tax exposure. Failure to create a proper plan could lead to unwanted tax burden.
Pre-immigration tax planning, however, is not a simple undertaking. It requires in-depth understanding of various rules and exceptions. Immigrants must also ensure that the plan is compliant with the U.S. tax law and the laws imposed by each jurisdiction where the individuals are planning to immigrate.
Join a panel of key thought leaders and professionals assembled by The Knowledge Group as they discuss current issues in immigration, tax and compliance that are vital to pre-immigration tax planning. Speakers will also provide the audience a review of the different planning tools and strategies that are used in the pre-immigration tax planning context to minimize tax exposure.
In a LIVE Webcast, the speakers will discuss:
- Residency Under U.S. Tax Law
- Taxation of U.S. Resident and Non-Resident Aliens
- Pre-Immigration Tax Planning Framework
- Multi-Jurisdictional Pre-Immigration Planning
- Pre-Immigration Planning Tools and Strategies
- Minimizing Gift & Estates Taxation Exposure
- Recent Trends and Developments
Alyssa Razook Wan, Attorney
Fowler White Burnett, P.A.
- Determination of U.S. domiciliary for gift and estate tax purposes.
- Classification of the “foreign trust” for U.S. tax purposes.
- Determination of whether the assets contributed to the trust constitute a completed gift for U.S. tax purposes.
- Transferring the assets of the foreign trust to the U.S.
- Reporting obligations.
Oscar Grisales-Racini, Shareholder
Fowler White Burnett, P.A.
- U.S. PRE-IMMIGRATION TAX AND TRANSFER PRICING PLANNING FOR CORPORATIONS
- U.S. PRE-IMMIGRATION TAX AND TRANSFER PRICING PLANNING FOR INDIVIDUALS
Leon Dutkiewicz, Jr., Managing Partner
D & H Global Tax Group
- Qualified business income deduction
- Limitation on deduction for interest
- Look-through rule applied to gain on sale of partnership interest
- Territorial system
- Deduction for foreign source portion of dividends received
- Treatment of deferred income upon transition to participation exemption system
- Current year inclusion of GILTI by US shareholders
- Deduction for foreign-derived intangible income and GILTI
Who Should Attend:
- Tax Attorneys
- Tax Preparers and Practitioners
- Tax Advisers
- Tax Accountants
- Tax Executives and Directors
- Tax Consultants
- Multinational Companies
- Other Related/Interested Professionals
Leon J Dutkiewicz, CPA, is the managing partner of D & H Global Tax Group, where he specializes in international tax. His education from Temple University has prepared him for a successful career in domestic and international tax services. His expansive knowledge of international tax affairs is demonstrated through his daily interaction with his staff and clients.
With proficiency in structuring global acquisitions/divestitures, analyzing income tax treaty benefits, assisting with transfer pricing implementation and managing multi-state tax issues, and compliance services, he demonstrates his thorough understanding of many complex tax laws. This expertise proves useful to his clients who have businesses operations in multiple jurisdictions or are Globally Mobile Individuals.
Leon’s substantial skills allow him to conduct seminars and teach international tax through various public mediums. He is frequently called upon to speak for professional organizations and has authored articles on international tax-related topics. In his free time he enjoys fishing, reading and traveling with his family.
Leon J Dutkiewicz, CPA, is the managing partner of D & H Global Tax Group, where he specializes in international …
Oscar Grisales-Racini is an international tax attorney with Fowler White Burnett, P.A.’s office in Miami, Florida. Mr. Grisales-Racini is licensed in the State of Florida, U.S., England & Wales, Ireland, the BVI and Colombia, and has an LLM in Federal Taxation from Boston University. Mr. Grisales-Racini is a frequent lecturer and writer on international taxation, transfer pricing and inbound/outbound tax planning matters.
Oscar Grisales-Racini is an international tax attorney with Fowler White Burnett, P.A.’s office in Miami, Florida. Mr. Grisales-Racini is licensed …
Alyssa Razook Wan represents citizens, dual-citizens, residents and non-residents in a variety of domestic and international tax and estate planning matters, such as pre-immigration planning, structuring investments in U.S. real property and structuring or restructuring estate plans through the use of trusts and business entities, often working closely with foreign co-counsel and trust companies to properly comply with the tax laws while obtaining the clients’ personal goals in a tax-favorable manner. She also represents charities in obtaining tax-exempt status and letter rulings from the Internal Revenue Service.
Before earning her Master of Laws in Taxation, Alyssa practiced commercial litigation and represented companies and individuals in a variety of business and real estate disputes. Drawing on this litigation experience, she represents clients in tax controversy and litigation matters before the Internal Revenue Service.
Alyssa obtained her Masters of Law degree in Taxation, at the University of Miami School of Law, her Juris Doctor degree, Cum Laude, from the Washington University School of Law in St. Louis and her Bachelor of Science degree in Industrial & Labor Relations from Cornell University.
Alyssa Razook Wan represents citizens, dual-citizens, residents and non-residents in a variety of domestic and international tax and estate planning …
Print and review course materials
Method of Presentation:
On-demand Webcast; Group-Internet Based
Experience in tax laws
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
1.5 CPE; 1.5 IRS-CE
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About D & H Global Tax Group
D&H Global Tax Group focuses on U.S. tax issues affecting corporations and individuals with international activities and/or significant investments in the U.S. Our familiarity with global regulations and issues are unmatched. We focus on problems and solutions daily, which are rare to local accounting firms, ensuring the most favorable results for our clients.
We combine traditional accounting skills with the ability to structure enterprises in a worldwide tax efficient manner as a result of years of collaborating with tax lawyers and accountants throughout the world. Our partner-run London office allows direct access to experts that help to produce optimal outcomes on a global basis.
About Fowler White Burnett, P.A.
Fowler White Burnett, P.A. is a full-service law firm formed in 1943 with its main office in Miami, Florida. Attorneys have expertise in a broad range of areas, including international taxation, estate planning and probate law; immigration; corporate, bankruptcy and real estate law; and commercial, maritime and insurance litigation. Attorneys and staff are fluent in many languages and frequently work with foreign counsel and trust companies to resolve cross-border issues. For more information, please visit the firm’s website: https://www.fowler-white.com/.