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Tax-Free Reconfigurations for Existing Nonresident Asset Ownership Structures

TAX-FREE RECONFIGURATIONS FOR EXISTING NONRESIDENT ASSET OWNERSHIP STRUCTURES

Cost Free
Presentation Length 1.0 hour

Recorded DateMarch 24, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Nonresident individuals with United States-situated assets often acquire the assets prior to getting full American tax advice that covers both income and estate/gift tax exposures. For these individuals, existing structures can create punitive tax exposures with traditional restructuring options risking significant tax imposition.

This program covers options for restructuring existing holdings in a tax-advantaged fashion, often with no type of United States tax imposition. This course will outline United States tax exposures for nonresidents in all aspects, then discuss the exposures created by straightforward transfers of existing holdings. This course then outlines options for the tax-free restructuring of existing holdings.

Learning Objectives:


  • Determine United States tax exposures for nonresidents in all aspects

  • Identify the exposure created by a straightforward transfer of existing holdings

  • Evaluate options for the tax-free restructuring of existing holdings

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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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