Nonresidents of the United States increasingly hold United States situs assets for assorted reasons, including globalization, investment diversification, having family within the United States, and even more reasons. With these reasons and considerations, a proper investment structure must incorporate income tax consequences in both the United States and the nonresident's home country. Critically, investment structures must also minimize exposures to United States estate and gift taxes which can create draconian consequences for those who structure ownership improperly.

This course will provide background on the pertinent rules for nonresidents for income/estate and gift purposes, then delve into structuring alternatives. The course will also address methods for altering existing improper structures, which is already an area where unwary taxpayers make missteps that lead to punitive American tax repercussions.

Learning Objectives:

• List relevant rules for income, estate, and gift tax purposes for non-U.S. residents holding U.S. situs assets


• Identify structuring alternatives for non-U.S. residents holding U.S. situs assets


• Evaluate methods for altering existing improper structures

NASBA Approved

CPAacademy.org (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

EA Approved

CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222