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Expatriation and the Exit Tax: Pros and Cons of Renouncing Citizenship

EXPATRIATION AND THE EXIT TAX: PROS AND CONS OF RENOUNCING CITIZENSHIP

Available Date(s)
Friday, December 06, 2024: 10:00AM EST

Cost Free
CPE Credits 1.0 hour
Subject Area 1.0 - Taxes (Federal Tax)
CE Credits 1.0 hour
Course Id# - HURS9-T-01190-22-O
Course Level Basic
Instructional Method Group Internet Based
Prerequisites None
Advanced Preparation None
Course Description

This program explores the tax ramifications of expatriation, which potentially impact both the expatriating individual and her future beneficiaries. We will begin with a discussion of background rules and alternatives for citizens to at least mitigate overarching American tax application—like Puerto Rican tax residency. Next, we will provide background on the “covered expatriates” to whom special tax rules apply, then explore the details and application of those tax rules.

Then the program will discuss the potential ramifications for future beneficiaries of the expatriate and special rules which can apply to the covered expatriate after United States ties have ceased. Lastly, the program will explore strategies for avoidance of “covered expatriate” status and timing considerations.

Learning Objectives:


  • Evaluate the tax ramifications of expatriation, which potentially impact both the expatriating individual and her future beneficiaries

  • Summarize the “covered expatriates” to whom special tax rules apply, then explore the details and application of those tax rules

  • Determine potential ramifications for future beneficiaries of the expatriate and special rules which can apply to the covered expatriate after United States ties have ceased

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Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
 

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NASBA Approved

CPAacademy.org (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

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EA Approved

CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

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Rimon is a highly selective entrepreneurial firm that combines the dynamic client service, teamwork, and agility of a high-end boutique law firm with the deep multidisciplinary experience of a large global firm. Our clients consistently receive exceptional representation across twelve countries and five continents, from our all-star team of corporate, litigation, tax, intellectual property, entertainment, and private client attorneys.

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Rimon's attorneys come with decades of experience before even joining Rimon. Rimon's attorneys were meticulously drawn from the top ranks of premier law firms, international corporations, and academia. They hold JDs, PhDs, LLMs, and MBAs from the best universities in the United States and abroad. They have worked on multi-billion dollar deals, have won bet-the-company litigation, and have run universities. Their experience and education ensure our clients receive consistently excellent and comprehensive counsel.