US tax compliance for your expatriate clients: Online course, September 2020


Sep 04-24

A new and unique perspective on the taxation issues affecting US citizens abroad

Unlike almost every other country in the world, the US obliges its citizens to make a return of their income and assets regardless of their place of residence. The introduction of FATCA and the more stringent bank account reporting has meant that even more US expats are conscious of ensuring that their tax affairs are in good order.

This course deals comprehensively with the compliance and planning issues, making it suitable for all professional advisers in this area, at all levels of experience.

In light of the current pause on face-to-face events we have redeveloped this course  for online learning. It will still be mostly live, one of the key values of our courses is the interactivity, and will be spread over six live modules, with podcasts, videos and webcasts to view in your own time.

Because tax should never been seen in isolation, we also feature content such as investment and retirement planning, two of the key areas where mistakes can be costly.

The course focuses on understanding the issues that face the American living abroad and wishing to be tax compliant. We do discuss some of the forms that need to be completed but this is not a series of lectures in how to complete those forms. No particular level of US tax experience is expected or taken for granted as everyone will be looking to fill the gaps in their knowledge.

Call +44 (0)1962 458058 or email for more details.

Course tutor

Timetable (all times UK summer time: GMT+1)

Friday, 4 September: Live via Zoom

4.00 – 4.30pm: Introduction – Meet John Richardson and other course participants

Tuesday, 8 September: Live via Zoom

4.00-6.00pm: Module 1 – “Are  you or have you ever been a US citizen? How about a permanent resident of the United States?”

– who is and who is not subject to the US regulatory regime. Before advising anybody to enter the US tax system this needs to be understood
– the difference between citizenship or residence for nationality purposes and citizenship or residence for tax purposes
– coping with the FATCA letter
– Sacred Trust: How To Counsel Americans Abroad In A FATCA and FBAR World

Thursday, 10 September: Live via Zoom

4.00-6.00pm: Module 2 – Relief From The US Extraterritorial Tax and Regulatory Regime

– US tax treaties and the savings clause
– when tax treaties may make US citizenship an advantage
– the Foreign Earned Income Exclusion
– Foreign Tax Credits
– Green Card Holders: Severing US tax residency through treaty tie breaker provisions

Tuesday, 15 September: Live via Zoom

4.00-6.00pm: Module 3 – Report Early! Report Often! Report Everything! Keep A Record Of What Your Report! The Most Common Information Returns and the attendant penalty regimes

– Form 5471: Carrying on business through a corporation is, well, UnAmerican
– Form 8938: Just you thought Mr. FBAR was enough
– Form 3520: What exactly is a foreign trust?
– Form 8621: Is that UK mutual fund really a sacred instrument of tax evasion?
– FinCEN 114: Mr. FBAR – as wholesome and American as apple pie
Form 1040: “All Forms And Schedules Lead To The 1040”

Thursday, 17 September: Live via Zoom

4.00-6.00pm: Module 4 – The Quiet American

– Americans are special: Special rules for retirement planning and investing
– The costs and difficulties of US tax compliance: Actual costs and opportunity costs
– the PFIC regime (interest charges on tax deferral)
– distributions from non-grantor foreign trusts (more interest charges on tax deferral)
– foreign grantor trusts (it all comes back to the grantor)
– Safe forms of investing for Americans (if there are any)

The US Person Abroad As An Entrepreneur

– Subpart F
– Pleading GILTI
– Fake income! Different Forms Of Fake Income: Taxation on income  never received
– the FBAR Marriage: the costs and opportunities of marriage between a US citizen and a non-citizen
– the tax filing category and why it matters: Married, Married Filing Separately, Single, Head of Household
– the 6013(g) Election: Should you or shouldn’t you (bring your foreign spouse into the US tax system)

Tuesday, 22 September: Live via Zoom

4.00-6.00pm: Module 5 – The Non-Compliant American: Understanding Compliance Options: Which option makes the most sense for your client?

– Filing on a going forward basis
– Streamlined Compliance (including the statement of non-willfulness)
– Relief procedures for Former citizens

Thursday, 24 September: Live via Zoom

4.00-6.00pm: Module 6 – Expatriation – Ceasing To Be A US Person

– understanding the US Expatriation Tax Regime
– the three different kinds of US exit taxes
– Renunciation and financial assets remaining in the United States