Transfer Taxes for the Multinational Individual (Completed)

Individuals with international holdings and activities most often pay primary focus to income tax consequences of their cross-border activities; this approach risks enormous transfer tax consequences, particularly for nonresidents with United States holdings. Noncitizen, nondomiciled individuals directly owning United States–situated assets face massive statutory exposure to United States transfer taxes, with minimal exclusion amounts ($60,000 for estate tax purposes) and tax rates quickly reaching 40%.

This program will cover the classification of individuals for transfer tax purposes and the scope of assets to which United States transfer taxes are applicable. The program will then discuss tax assessment, categories of exempt assets, and estate and gift tax treaty interplay with statutory rules.

Topics Covered

• Classifying individuals for transfer tax purposes
• When transfer taxes are applicable
• Tax assessment
• Categories of exempt assets
• Estate and gift tax treaty interplay with statutory rules

Learning Objectives

• Recognize how individuals are classified for United States estate and gift tax purposes
• Identify estate and gift tax exposures for noncitizen nondomiciled individuals
• Analyze the impact of estate and gift tax treaties on estate and gift tax exposures
• Define United States rules for foreign trusts
• Understand functional complexities arising for United States-based taxpayers with foreign holdings

Level
Intermediate

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic understanding of international taxation

Advance Preparation
None