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Structuring United States Investments by Foreign Taxpayers

STRUCTURING UNITED STATES INVESTMENTS BY FOREIGN TAXPAYERS

This webinar was previously offered for 1 hour and has expanded to 1.5 hours
Cost $22.50
Presentation Length 1.5 hours

Recorded DateApril 22, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The United States imposes a multitude of tax requirements on United States taxpayers with foreign investments, whether through information reporting requirements or, in the case of foreign corporations, immediate inclusions for what otherwise would be deferred income.  Rather curiously by juxtaposition, foreign taxpayers making investments in the United States often find favorable tax provisions, including exemptions from the tax for many capital gains items.  However, it is critical to properly structure United States investments by foreign taxpayers, looking at relevant considerations and standard techniques.

Learning Objectives:


  • Recognize Effectively Connected Income (ECI)

  • Recognize the basic structure of US income tax treaties

  • Recall how foreign trusts are taxed

  • Recognize common ownership 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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