Late in the evening of April 20, 2020, President Trump announced by Tweet that he…
When it comes to getting your clients to the United States you’re the master. But what happens when that conversation turns to the client’s financial planning? Global migration can lead to some tricky tax situations which may not always get the attention they deserve. In this webinar, senior accountants from Moss Adams LLP will address some tax issues that every immigration lawyer should be aware of.
In this presentation, our speakers will discuss planning for entry into the U.S. tax system, including a high-level overview of income, and estate and gift tax considerations. We will address the U.S. foreign disclosure rules and the US anti-deferral regimes. And we will briefly touch on tax planning prior to the surrender of U.S. citizenship or long-term permanent resident status.
Video of the program is located below.
Estate and Gift Tax Issues.
- Planning for move to U.S.
- Estate/gift tax residency.
- Estate/gift tax applicability for NRA’s and for U.S. residents.
- Planning for U.S. gift/estate tax applicability – considerations of trusts/gifting before a move.
- Planning for the U.S. foreign disclosure rules – streamlining/consolidation of foreign assets/entities before a move.
Considerations Prior to moving to U.S.
- Considerations related to negotiating compensation arrangements/benefits/tax equalization agreements/etc. before moving to the U.S.
Determining taxation and differences of taxation for U.S. residents vs. non-residents.
- U.S./State taxation of foreign nationals.
- U.S. residency vs non-residency for income tax purposes.
- U.S. taxation of U.S. persons vs NRAs.
- Substantial Presence Test.
- Closer Connection Exception.
- Dual Status Returns.
- First Year Elections.
Our guest speakers.
Satoko Valdes, Senior Manager, Moss Adams LLP.
Satoko has been providing inbound international tax compliance and consulting services since 1996. She has managed inbound and outbound corporations and individual tax returns, tax equalizations, and international consultations. Prior to joining Moss Adams, Satoko led the Japanese tax practice of a Big Four firm’s Seattle office. Satoko is a board member of the Japan America Society, a member of the Japan Business Association and the Tax Advisory Board of Golden Gate University.
Stephanie Hathaway, Tax Partner, Moss Adams LLP.
Stephanie is a leader in the firm’s International Tax and Private Client Services practices. Her experience includes over twenty years in public accounting and ten years in business management and administration. Stephanie works closely with international legal, accounting and financial professionals to coordinate cross-border planning and compliance for individuals, trusts, estates, and closely held businesses. In addition, she has presented on a wide variety of international topics for Moss Adams professionals and for outside organizations. In 2000 Stephanie received the Moss Adams Technical Excellence Award in Taxation for consulting and analysis regarding the expatriation provisions of Internal Revenue Code Section 877A and for preparing Private Letter Ruling requests under Section 877A for individuals giving up US citizenship or US long-term permanent resident status.
Brian Steuber, Partner, Moss Adams LLP.
Brian Steuber has been in public accounting for over 22 years, with experience related to individual income tax matters, focusing specifically on international assignment and private client tax services. Prior to joining Moss Adams, he has spent his entire career within the Big 4.
Brian has worked with small to large Fortune 50 clients with respect to their international assignment programs addressing the complex individual tax planning and compliance matters, corporate reporting and withholding issues, tax-efficient delivery of compensation in multiple jurisdictions, tax reimbursement schemes and cross-border equity issues. He has also provided wealth management services to ‘C-Suite’ and other key executives regarding stock options, equity transaction planning, AMT tax planning, and other complex investment tax issues.