Make sure your dual resident clients are aware of potential tax issues when it comes to transfers of appreciated property to foreign entities.
A foreign corporation is a PFIC if 75% or more of its gross income is passive income or at least 50% of the average value of its assets are of a type that produce passive income. Common examples of PFICs are foreign mutual funds and shares in foreign holding companies that hold stocks and bonds. Passive income means foreign personal holding company income which includes interest, dividends, rents, royalties and annuities, among other sources of income. This white paper reviews why dual residents need to be aware of taxation of PFICs and potential CFC overlap concerns and discusses how transfers of appreciated property to a foreign entity by a U.S. person may result in adverse income tax consequences to a dual status client; thus, such transfers should be carefully evaluated.
Agenda
Faculty
Anthony F. Vitiello, Esq.
Connell Foley LLP
- Partner and chairman of the Taxation and Estate Planning Group of Connell Foley LLP (Resident in the Roseland, NJ office)
- Practice is dedicated to sophisticated tax planning for individuals, businesses, estates and trusts, with a particular emphasis on national and multinational estate planning, as well as as-set protection planning
- Lectures extensively and frequently publishes in legal and business journals on a variety of tax and estate planning issues, including those related to federal estate, gift and income tax issues, wealth preservation, trusts, and a multitude of other planning techniques
- Admitted to practice in six states, the District of Columbia and United States Tax Court
- Recognized for the past 10 years in “Best Lawyers in America” in the areas of trust and estates, trust and estates – litigation, and tax litigation and controversy
- LL.M. degree in taxation; J.D. degree, New York University
- Can be contacted at 973-840-2433 or [email protected]
All of your training, right here at Lorman.
Pay once and get a full year of unlimited training in any format, any time!
- Live Webinars
- OnDemand Webinars
- MP3 Downloads
- Course Manuals
- Audio Recordings*
- Executive Reports
- White Papers and Articles
- Sponsored Live Webinars
Additional benefits include:
- State Specific Credit Tracker
- Members Only Newsletter
- All-Access Pass Course Concierge
* For audio recordings you only pay shipping
Questions? Call 877-296-2169 to speak with a real person.
Thank You!
Download White PaperMore Program Information
Access to all training products $699/year
Unlimited Lorman Training
With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!
Easy Registrations
Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.
Invest in Yourself
You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.
