International Individual Fundamental Taxation

General Description:

Participants will learn the fundamental individual tax issues for a foreign individual investing in the U.S. (inbound) or a U.S. individual investing abroad (outbound).

Learning Objective:

After completing this course the participant will be able to:
Inbound

• Distinguish outbound vs. inbound transactions.
• Determine the tax classification of a foreign individual coming to the U.S. from a Code perspective and from a treaty perspective.
• Apply sourcing of income rules from an investment perspective and the performance of personal services.
• Ascertain the important real estate elections and planning a foreign person needs to be aware of when investing in U.S. real estate.
• Identify the estate planning issues of a foreign person.

• Explain the direct foreign tax credit.
• Apply the §911 exclusion and housing exclusion for a U.S. expatriate.
• Explain the taxation of a U.S. person investing directly in a foreign security, through an entity, through a foreign trust, or in a foreign mutual fund (PFIC).
• Recognize the U.S. income tax issues with foreign life insurance products and foreign retirement plans.
• Summarize the estate planning issues for the non-citizen spouse.
• Identify expatriation issues as applied to the long-term resident alien.
• Recognize the ethical and legal issues when a client has unreported foreign income.

Instructors:

Mark Merric is a CPA and an attorney and holds a master of taxation degree. He is an adjunct professor at the University of Denver Graduate Tax Program and the University of Colorado Denver MS in Taxation program, and a lecturer for Fudan University’s Master of Taxation program (second ranked in China). He manages his own law firm where he concentrates on domestic and international business transactions, international taxation, and estate planning. He has spoken nationally and internationally more than 600 times, authored and co-authored more than 80 articles nationally, and is quoted in the Wall Street Journal, Forbes, and the Boston Herald.

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