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NAVIGATING AN IRS TAX AUDIT
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VIRTUAL CURRENCY TRANSACTIONS AND FORM 1040
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Free cpece webinars
Expatriation, Exit Tax, and New Section 2801 Regulations

EXPATRIATION, EXIT TAX, AND NEW SECTION 2801 REGULATIONS

Available Date(s)
Friday, February 14, 2025: 9:30AM EST

Cost Free
CPE Credits 1.5 hours
Subject Area 1.5 - Taxes (Federal Tax)
CE Credits 1.0 hour
Course Id# - HURS9-T-01777-25-O
Course Level Basic
Instructional Method Group Internet Based
Prerequisites None
Advanced Preparation None
Course Description

This course covers the full range of tax issues associated with expatriation from the United States, with special emphasis on Section 2801 regulations finalized in January 2025. This program explores the tax ramifications of expatriation, which potentially impact both the expatriating individual and their future beneficiaries.

The first topic of discussion will be background rules and strategic alternatives for citizens to at least mitigate overarching American tax applications like Puerto Rican tax residency. Next will be an introduction to the “covered expatriates” to whom special tax rules apply, and we will continue by exploring the details and application of those tax rules. The program also covers the Section 2801 ramifications for future beneficiaries of the expatriate as well as special rules that can apply after ties to the United States have ceased.

Learning Objectives:


  • Evaluate the tax ramifications of expatriation, which may impact the expatriating individual and their future beneficiaries

  • Identify the criteria for "covered expatriates" to whom special tax rules apply, including the details and application of those tax rules

  • Describe ramifications for future beneficiaries of the expatriate along with special rules that 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 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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Frequently Asked Questions
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  • CPE is available to all eligible participants within 24 hours of each webinar.
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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.

Rimon's consistent excellence, commitment to the community, and innovation have been internationally recognized, including by Harvard Law School, Stanford Law School, Chambers, Best Lawyers, Super Lawyers, the Financial Times Innovation awards, the Atlantic, the American Bar Association's Legal Rebels, the Economist, the Recorder, and many more.

Rimon’s clients range from cutting-edge technology startups to financial institutions and Fortune 100 companies.

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.