Multinational individuals will most often focus on income tax consequences of multinational activities; this approach risks minimization of transfer tax consequences. Non-resident individuals directly owning United States–situated assets face statutory exposure to United States transfer taxes. Given minimal exclusion amounts ($60,000 for estate tax purposes) and tax rates quickly reaching 40%, exposures in this context are enormous.
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.
Registration $15 - Limited complimentary registration for first-time guests.
No charge for EPC Canada Members.
Patrick is a partner with Culhane Meadows, and practices exclusively in the area of international taxation. Patrick works both with international-domiciled individuals and businesses entering the United States market and United States taxpayers with international connections. His diverse international tax background –previously having been a partner both at a law firm and an accounting firm – gives him a full understanding of the tax complexities posed by multinational connections, and his familiarity with the minutia of international tax law allows him to optimize tax results for his clients. Patrick holds a Juris Doctorate from Vanderbilt University Law School and a LL.M. from New York University School of Law.
Patrick assists individual clients in areas including residency planning, asset ownership structuring, and minimization of global income tax bills for foreign-sourced income items. For businesses, Patrick’s representation covers an extensive scope of multinational transactions, including classification of foreign entities, options for structuring multinational transactions, and minimization of American anti-deferral tax mechanisms. Patrick assists his clients in all areas where their international ties are a relevant factor.
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