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BNA Presents a Dialogue With IRS Officials on Expatriation, Foreign Trust, and Community Property Issues.

ARLINGTON, Va., Jan. 5 /PRNewswire-USNewswire/ -- IRS Officials will meet with leading private sector advisors to explore the US Internal Revenue Code's provisions relating to expatriation, community property, and foreign trusts in a BNA Tax & Accounting-sponsored webinar, Dialogue with IRS Officials on Expatriation, Foreign Trust, and Community Property Issues, on January 19, 2010.

(Logo: http://www.newscom.com/cgi-bin/prnh/20090114/DC59060LOGO-b )

Directed towards tax professionals who advise high net worth individuals, this webinar will cover issues arising in expatriation, issues related to the use of foreign trusts, and the US income tax consequences to US and nonresident alien spouses resulting from the interaction of a special Internal Revenue Code section to local community property law; BNA will moderate a panel of IRS specialists who will overview these particular sections and then respond to questions related to their application. The private practitioner panelists then will comment and ask follow-up questions.

"The US Internal Revenue Code provisions governing cross border planning for high net worth individuals are complex and opaque," says Alan Granwell, the webinar moderator and Partner with DLA Piper LLP. "In planning, a professional advisor needs to understand the US and local rules in analyzing a transaction and then rationalize their interaction."

The webcast will specifically cover issues related to:

Expatriation. Expatriation relates to certain US citizens who relinquish their US citizenship and certain "green card" holders that cease to be lawful permanent residents.

The basic regime of section 877A will be summarized, including to whom it applies, when it applies, how it applies, exceptions to its application, and procedural issues related to returns and forms that are required to be filed in connection with an expatriation.

Issues arising under Notice 2009-85, which provides guidance for expatriates (US citizens and certain "green card" holders ), will be highlighted by the principal drafters of that Notice.

The application of section 877A to "green card holders" will be specifically considered, and will include a discussion of which green card holders are encompassed by the provision, how green card holders can relinquish their lawful permanent resident status, how green card holders may inadvertently become subject to section 877A, and the interaction of section 877A and bilateral income tax treaties.

Immigration rules are central to expatriation. These rules and their interaction with the US tax rules will be overviewed by an immigration lawyer experienced in this area.

Community Property. A US individual may be married to a nonresident spouse and domiciled in a community property jurisdiction. That jurisdiction may provide rules as to which assets are treated as community property and which assets are treated as separate property. The US income tax effect of these local rules may be modified by section 879 of the Internal Revenue Code (dealing with community property taxation under the Code). An IRS attorney responsible for providing guidance under this section will overview section 879 and its application, and discuss when and how section 879 interacts with local community property law.

Foreign Trusts. The webcast will provide an overview of the foreign trust modifications that are contained in Title V, Foreign Account Tax Compliance, which is contained in HR 4213, Tax Extenders Act of 2009, recently passed by the House of Representatives. An IRS attorney familiar with these provisions will summarize the proposed modifications and discuss their impact on existing law.

Panelists include:

Lara Banjanin

Attorney

Branch 1

Office of the Associate Chief Counsel (International)

Internal Revenue Service

Washington, DC

M. Grace Fleeman

Senior Technical Reviewer

Branch 1

Office of the Associate Chief Counsel (International)

Internal Revenue Service

Washington, DC

Joseph S. Henderson

Attorney

Branch 1

Office of the Associate Chief Counsel (International)

Internal Revenue Service

Washington, DC

Paul Hocking

Chairman

Frank Hirth plc

London, England

Steve Trow

Partner

Trow & Rahal, PC

Washington, DC

Willard (Bill) W. Yates

Attorney

Branch 1

Office of the Associate Chief Counsel (International)

Internal Revenue Service

Washington, DC

The 60-90 minute webinar will start at 10:00 am ET. Attendees will have the opportunity to ask questions during the webinar and CLE/CPE credits are available.

To register for this webinar and obtain further information about CLE and CPE credits, go to: http://www.bnatax.com/CLE-CPE-Information/ or call 1-800-372-1033, menu Option 6, then Option 1. The fee is $249 for BNA subscribers, $299 for nonsubscribers.

To receive automatic email notification of upcoming BNA webinars that may be of interest to you, go to: http://www.bna.com/emailsignup.htm

About BNA Tax & Accounting Webinars

BNA Tax & Accounting is the foremost source of tax and accounting research, news, practice tools, and guidance for tax attorneys, CPAs, corporate tax managers, estate planners, and financial accountants. Designed for today's busy practitioners, our webinars offer the same expertise and relevance that are the hallmark of all BNA Tax & Accounting resources. In just 60-90 minutes, practitioners gain in-depth knowledge on a current tax or accounting topic from experts in that area -- and benefit from practical applications that can be put to work immediately. Conference attendees have the opportunity to ask the speakers questions, and may be eligible to earn CLE or CPE credits -- all from the convenience of their own office or conference room.

SOURCE BNA Tax & Accounting
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