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Factors to Consider in Structuring Nonresident Asset Holdings

FACTORS TO CONSIDER IN STRUCTURING NONRESIDENT ASSET HOLDINGS

Cost Free
Presentation Length 1.5 hours

Recorded DateMay 17, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Nonresidents of the United States increasingly hold United States situs assets for assorted reasons, including globalization, investment diversification, having family within the United States, and even more reasons. With these reasons and considerations, a proper investment structure must incorporate income tax consequences in both the United States and the nonresident's home country. Critically, investment structures must also minimize exposures to United States estate and gift taxes which can create draconian consequences for those who structure ownership improperly.

This course will provide background on the pertinent rules for nonresidents for income/estate and gift purposes, then delve into structuring alternatives. The course will also address methods for altering existing improper structures, which is already an area where unwary taxpayers make missteps that lead to punitive American tax repercussions.

Learning Objectives:


  • List relevant rules for income, estate, and gift tax purposes for non-U.S. residents holding U.S. situs assets

  • Identify structuring alternatives for non-U.S. residents holding U.S. situs assets

  • Evaluate methods for altering existing improper structures

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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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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