Mr. August will discuss the various tax planning issues and tax compliance burdens that U.S. citizens and residents face in moving overseas either on a temporary work assignment or indefinitely. On the income tax side, discussion will focus on the use and limitations on claiming foreign tax credits, the foreign earned income and housing cost exclusion, foreign deferred compensation arrangements and the income taxation of U.S. owned or controlled foreign-based entities and corporations. Double tax issues will be highlighted including relief provided from double taxation under U.S. tax treaty. The tax compliance side is quite formidable as various extensive reporting regimes are implicated including Bank Secrecy Act reporting such as FinCEN Form 114 (FBAR), specified foreign assets (Section 6038D), FACTA reporting for interests in foreign financial institutions and non-foreign financial entities, as well as reporting with respect to foreign trusts, estates and gifts. Mr. August will also discuss the “International Estate Planning Environment” and general considerations in merging a U.S. estate plan with that of the migrating client’s new jurisdiction of residence.
- Jerald David August, Esq, Kostelanetz & Fink LLP, New York, NY
42 W 11th St
Wilmington, DE 19801
Google map and directions