This webinar will provide tax advisers with a practical guide to planning tools and techniques for clients who are nonresident aliens contemplating residency/citizenship changes rendering them United States taxpayers. This seminar will discuss the differences in tax scope between nonresident aliens and United States taxpayers, both for income tax and estate/gift tax purposes. The seminar will also detail strategies for minimizing income and transfer tax post-residency, including basis strategies for non-U.S. situs assets, structuring “drop-off” trusts, and planning for the possibility of the nonresident alien’s return to their country of origin.
Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.
Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPAacademy.org on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law. His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.
Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.