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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

CPE Processing Fee$25.00
Webinar TranscriptionN/A
Presentation Length Hour(s)1.0 hour
CPE Credits 1.0 hour
Subject Area 1.0 - Taxes (Federal Tax)
CE Credits 1.0 hour
Course Id# - HURS9-T-01190-22-S
Course LevelBasic
Instructional MethodQAS Self-Study
PrerequisitesNone
Advance PreparationNone
Recorded DateJune 22, 2023
Date OfferedJune 22, 2023
Expiration DateJune 22, 2024
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 applications—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



FOR RECORDED COURSES WITH VIDEO

Download any course document(s) (below) which may include handouts, glossary, transcripts, etc. Follow any prompts contained in the documents to help you complete the course. Most documents are searchable.

Play the recording, noting the sectional guides indicating where topics on the agenda are covered and the prompts to pause video playback to respond to a review question (located below the video playback area). The timestamps for review questions are also noted below.

Upon completing the video and successfully answering all review questions, you will then take the final exam.

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Handout Materials
Presentation Slides
Additional Materials
Glossary
Review Questions
Review Questions
QUESTION 1: 0:04:55 minutes
QUESTION 2: 00:30:00 minutes
QUESTION 3: 00:33:15 minutes
Frequently Asked Questions
  • CPAacademy self-study courses are online.
  • The self-study format allows you to a) access the material online 24/7 and b) study at your own pace.
  • Per NASBA guidelines, you have one year from date of purchase to complete each program.
  • Complete your final exam at any time and get graded instantly. You can retake the exam at no additional charge (unlimited attempts).
  • Print your own certificate of completion on the spot upon passing the exam.
  • Grading policies: a) courses have a minimum passing score 70% b) test takers will not be provided feedback on failed exams.
  • Upon achieving a passing score, test takers will be notified of the correct answers to the questions missed.

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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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About Our Presenter

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McCormick Tax was established in 2022 to serve clients worldwide – no matter their size – on any and all needs in the United States international tax context. Our clients range from multi-billion dollar business enterprises to cost-sensitive startups, high-net-worth individuals to those with lower net worths but discrete (and often complex) international tax needs. Our firm’s founder – a non-accountant international tax attorney - has previously served as a partner (exclusively focused on international tax work) at an AmLaw200 law firm, a boutique tax, trusts and estates law firm, and a tax-focused accounting firm, giving extensive experience both with every aspect of international tax rules and every type of client with international tax needs. Transitioning from a large firm to an independent practice has also enabled our firm’s practitioners to significantly reduce their hourly billable rates – creating efficiencies for our clients and allowing us to work with clients of all sizes.

Our firm covers every aspect of United States international tax, trusts, and estates rules; we also assist our clients on more domestic-oriented United States tax needs. We work directly with clients; we also serve as “outsourced international tax counsel” for accounting, law, and advisory firms around the world. In that role, we assist wherever beneficial with those firms’ client needs in the international tax context, allowing those firms to hang onto clients/continue to work with those clients rather than losing them to firms with internal international tax teams. Our firm’s independent status gives us enormous flexibility in how we structure representations, ensuring we can serve in optimal fashion for whatever client needs arise.