International Tax Lunch: Inbound Executives of Foreign Corporations

Description

Tax planning gets complicated when you are working with a nonresident coming to the U.S. to work for a while. You need to plan for the transition from nonresident to resident (with different rules for income tax and estate/gift tax), a period of years while the individual is a U.S. resident, followed by an expected return to nonresident status.

Identifying the issues early helps you to minimize tax costs and U.S. tax compliance costs. This session will walk you through the questions that come up—and how to address them—when a foreign executive or other individual comes to the United States as a long-term but temporary resident.

Highlights

• Definition of "resident" and "nonresident" for income tax and estate/gift tax.
• Starting and ending dates for resident status.
• Use of tax treaties and the closer connection test to control resident/nonresident status.
• Expatriation tax rules as they apply to green card holders.
• Reporting requirements for PFICs, CFCs, and foreign trusts.

Objectives

• Identify actions to take before the individual becomes a U.S. resident in order to minimize U.S. income tax and U.S. income tax return complexity.
• The transition years: when does residency start? How do you prepare the tax return for the year of transition from nonresident to resident, or resident to nonresident?
• What type of estate tax and gift tax planning is appropriate and how do the rules work while they are living in the United States?
• The importance of getting the "right" type of visa: why a green card creates tax risks. 

Designed For

Lawyers and CPAs.