Foreign Investment in the United States: Tax and Related Matters

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Overview

8.0 Credits
IN-PERSON

This seminar covers what you need to know to help your foreign clients navigate the U.S. tax waters after the Tax Cuts and Jobs Act of 2017. We will review the broad spectrum of the U.S. tax and reporting rules and planning considerations applicable to foreign persons investing and doing business in the United States and also how to plan for the possibility that a foreign person may become a U.S. person. 

This session utilizes updated course materials and supplements that include recent cases and tax law changes. The presenters will draw upon their many collective years of inbound international tax and estate planning practice experience to provide attendees with the knowledge needed to assist clients with creating, troubleshooting and properly reporting (both timely and “catch-up”) their U.S. investment structures and minimizing associated taxes.  

The material presented in this session, as well as Estate and Gift Taxation of Nonresident Aliens in the US session is intended to be complementary rather than significantly overlapping.

Objectives

When you complete this course, you will be able to:
  • Acquire knowledge and practical how-to approaches on foreign investment in the United States and numerous types of passive and active business investments

Major Topics

Topics of discussion will include:

  • Classification of the Investor as a U.S. Income Tax Resident or Nonresident.
  • Classification of Foreign Entities.
  • Taxation of Passive U.S. Source Income.
  • The Portfolio Interest Exemption Rules.
  • Taxation and Classification of U.S. Business and Real Estate Income.
  • Withholding—Passive Income, Real Estate, Partnerships.
  • Classification of Trusts—Foreign or Domestic.
  • Income Taxation of Foreign Trusts.
  • Tax Planning Structures—Income Tax Considerations.
  • Pre-Immigration Planning—Income Tax Considerations.
  • Use of U.S. Income Tax Treaties.
  • Selected Filing and Disclosure Requirements.
  • Update of IRS Voluntary Disclosure Programs.

Designed For

Any professional who has the opportunity to advise foreign individuals or foreign entities with respect to U.S. investments or business activities

Prerequisite

None

Advanced Preparation

None
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FICPA EZMaterials! Paper manuals will not be provided at this session, you’ll need to download the EZMaterials as searchable PDFs to your laptop, tablet or other device before the event. 

For more information feel free to call the FICPA Member Service Center at 800-342-3197 or 850-224-2727.