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Article Written for:  Florida CPA Today Magazine, FICPA Florida Institute of Certified Public Accountants

For U.S. income tax purposes, foreign trusts are treated as non-resident/non-citizens (NRNC), subject to U.S. income tax only on U.S. source income.[1]

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Article Written for:  Florida Bar Journal

A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to U.S. income tax only on U.S. source income.[1]

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Foreign Asset Protection and Tax Planning
In this seminar, we discuss protective offshore structures and related tax strategies. Attendees will learn how best to establish and fund foreign trusts and business entities while maintaining U.S. tax efficiency. The advantages of offshore vs. domestic trust planning will also be discussed. Topics will include choosing jurisdictions, choice of governing law, expatriation, and pre-immigration planning.

Wednesday, November 29th @ 12 Noon ET
Visit the Estate Planning Council of Naples website for more information.
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Foreign or Domestic: Which Asset Protection Trust Is Right For You?
In this seminar, we present an overview of asset protection trusts, including their protective characteristics and taxation under U.S. law.  Attendees will learn the pros and cons of domestic vs. offshore trust planning.  The discussion will include how to best implement the unique advantages of both foreign and domestic law.

Thursday, July 14th @ 12 Noon ET
Register for this (no cost) live seminar.
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Tax Expatriation of People and Assets
This seminar covers the U.S. tax impact of expatriation. Discussions will cover both the expatriation of (i) U.S. citizens and permanent residents and (ii) U.S. assets. The deemed sale imposed on expatriating individuals will be explained and avoidance strategies discussed. Attendees will also learn how to avoid tax regarding the transfer of assets abroad.

Wednesday, September 22nd @ 12 Noon ET
Register for this LIVE (no cost) seminar.
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Domestic and International Asset Protection for the CPA
In this seminar, we discuss which domestic and international jurisdictions best protect business owners and investors and how the U.S. courts have interpreted such protections. Related tax issues are also discussed. Attendees will learn about the strengths and weaknesses of LLCs and trusts available domestically and abroad.

LIVE from the St. John's University Campus
Tobin School of Business Bent Hall / Room 201
8000 Utopia Parkway
Queens, NY 11439

Monday, August 30th @ 6 PM ET
Visit the NYSSCPA website for more information.
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Understanding the GILTI Tax (Global Intangible Low-Taxed Income)
The US Tax Reform Act broadened the regulatory net on deferral of offshore income and introduced a new category of income, known as GILTI. In this seminar, we discuss who may be exposed to the GILTI tax and how to limit its impact.

Tuesday, June 29th @ 12 Noon ET
Register for this LIVE (no cost) seminar.
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Asset Protection for Physicians
Physicians are particularly exposed to professional liability claims and face unique complexities in protecting their assets. In this seminar, we discuss asset protection strategies tailored to insulate physicians, including exemption and entity planning, both domestic and offshore. Attendees will also learn about the interplay of professional liability insurance and protective planning.

Wednesday, June 23rd @ 12 Noon ET
Register for this LIVE (no cost) seminar.
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Asset Protection for the Single Person
In Florida and other states which protect assets jointly titled to married couples, such titling is often the foundation of asset protection. In this seminar, we discuss the legal challenges of structuring protections for unmarried individuals. Attendees will learn about protective options available to single people and couples living in states not offering titling by the entireties.

Thursday, June 17th @ 12 Noon ET
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Tax Issues Raised by the Onset of U.S. Business Operations
In this seminar, we discuss the tax issues relevant to (i) businesses considering U.S. operations and (ii) their owners and executives. Attendees will learn about cross-border corporate tax concerns, pre-immigration planning, and the U.S. estate and gift tax.

Jim Dawson is CEO of Global Tax Focus, an international tax strategy and compliance practice based in Atlanta. He is a Certified Public Accountant and an international business and tax advisor to global enterprises. He can be reached at (404) 855-0795.

Wednesday, May 26th @ 12 Noon ET
Register for this LIVE (no cost) seminar.
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Forster Boughman & Lefkowitz

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