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Expatriation: The Exit Tax and Planning Opportunities, What the Sophisticated Advisor Must Know



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Whether it’s due to the November elections or the onerous U.S. tax reporting and filing obligations, there are U.S. citizens and long-term greencard holders who wish to relinquish their U.S. citizenship and long-term residency in favor of other jurisdictions. For “Covered Expatriates” expatriation may result in adverse tax consequences.  In his exclusive LISI Webinar, Eli Akhavan will discuss who qualifies as a “Covered Expatriate,”,the tax consequences of expatriation for a Covered Expatriate (the “Exit Tax”) and planning opportunities to minimize the tax bite.  Special attention will be given to how a Covered Expatriate’s trust and estate planning will affected.

Topics to be discussed include:

·         Mechanics of relinquishing US citizenship or long-term residency

·         How does a person become a Covered Expatriate for tax purposes under the three tests:

o   Average tax liability

o   Net worth

o   Certification of compliance

·         Exceptions to the definition of a Covered Expatriate

·         Exit Tax consequences of becoming a Covered Expatriate

o   Mark-to-Market

o   Specified tax deferred account

o   Deferred compensation

o   Interests in nongrantor trusts

·         Estate and Gift Tax consequences under Section 2801 for Covered Expatriates

·         Planning strategies prior to expatriation

 

Eli Akhavan is Senior Counsel in the New York office of Norton Rose Fulbright, and focuses on tax and estate planning for high net-worth US and non-US clients.

Eli advises international individuals and families with respect to tax and estate planning for their U.S. assets and beneficiaries. Eli also advises cross-border clients on all aspects of international estate matters, including foreign trusts, pre-immigration and expatriation planning, and on planning for the purchase of U.S. residential and investment real property. Eli has considerable knowledge of the reporting requirements applicable with respect to foreign financial accounts and assets and with respect to FATCA and its global equivalent, the Common Reporting Standards (CRS). Eli's practice includes advising clients on the formation of private trust companies for purposes of wealth management and privacy.  

Additionally, Eli counsels U.S. and non-U.S. individuals and families on implementing domestic and foreign asset protection structures involving trusts and other vehicles to protect clients from creditors. Eli advises clients on domestic asset protection trusts in the U.S. in jurisdictions such as Nevada, Delaware and Wyoming, and on foreign asset protection trusts in jurisdictions such as the Cook Islands and Nevis. Eli also integrates innovative private placement life insurance planning into his clients' plans as an estate and asset protection tool.        

With respect to ultra-affluent U.S. clients, Eli employs sophisticated wills and trusts, as well as closely-held entities, to enable his clients to transfer their wealth at a minimum tax cost. Eli also advises U.S. clients on Puerto Rico's Acts 20 and 22 which allow clients to achieve income tax savings by relocating to Puerto Rico. 

Eli has served as professor of International Taxation at St. John's University Law School. He is a recognized authority on tax and estate planning matters having been quoted by the Wall Street Journal, Fox Business and Bloomberg News. Most recently, he has lectured in the Caribbean and the Middle East on asset protection and cross-border planning matters. Eli has written numerous articles that appear in legal publications in the US and abroad.



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