CPA - medium firm
CPA - large firm
Enrolled Agent
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The world is getting smaller; it is increasingly common for United States citizens and residents to have international connections, based on a multitude of factors (such as having dual citizenship, holding assets overseas, or having family members living in other countries). Nonresident aliens also hold United States investments with increasing regularity. Estate plans of multijurisdictional clients must properly incorporate rules of all relevant countries – both for tax and functional purposes. Cognizance of these issues is critical for CPAs assisting clients with their global financial considerations.
This program will provide a general introduction to estate planning concepts and procedures for international clients. Transfer tax differences between citizens, residents, and nonresident aliens will be discussed, exploring planning techniques most relevant for each (including the applicability of estate and gift tax treaties). The program will also cover common concerns in multijurisdictional planning, such as common American techniques which can create negative functional ramifications under the laws of other countries. The program will close with a discussion of best practices in multijurisdictional planning, including the benefits of foreign advisors in this context.
Patrick McCormick, JD, LLM
Rimon PC
Partner
[email protected]
(215) 630-0861
Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.
Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.
Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.
Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
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