On March 15, I was delighted to present cross-border tax topics of interest for the Financial Planning Association (FPA). FPA is a well-known membership organization for certified financial planner professionals and those engaged in the financial planning process. It provides its members with practice support, learning, advocacy, and networking.
As a tax professional, with 40 years of experience, it can be a bit challenging to give a broad overview with just enough detail for an audience that is not comprised of international tax professionals but who can benefit their clients by understanding tax issues that impact them. We are now living in a global economy and working with international families having multiple nationalities. My goal for the presentation was to heighten awareness of important cross border tax issues that commonly affect such groups.
Listen to the Presentation
I was so pleased with how this turned out and was given permission to share the presentation on my website. You can access the presentation and see the accompanying slides at this link.
What I Covered – Tax Issues of Importance on “Entry” to and “Exit” from the United States
My talk focused on significant US tax issues, for two distinct groups: those wishing to “enter“ the United States and those wishing to “exit” the United States. Points of discussion for the first group included pre-immigration tax planning techniques such as use of a drop-off trust with PPLI, and important points in making a decision about obtaining a green card, or becoming a US tax resident by prolonged physical presence in the United States, or whether it is best to remain a nonresident alien individual. Delegates were very interested to learn about the expatriation tax regime for those wishing to “exit” the United States by relinquishing a green card or US citizenship.
The presentation concluded with a discussion of our favorite penalty fundraiser, Mr. FBAR. We have had very significant recent decisions concerning FBAR, including a landmark decision from the United States Supreme Court at the end of February. We also had a very recent case, decided much to the chagrin of the Internal Revenue Service, concerning how a treaty tie-breaker clause might save a taxpayer from FBAR penalties!
The FPA delegates in attendance had many interesting questions, which are also part of the presentation. Hope you enjoy it.
Posted March 18, 2023
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