When foreign high-net-worth individuals immigrate to the United States, comprehensive planning is typically required to minimize exposure to U.S. income taxes, while taking into account any non-U.S. tax consequences that may result from relocation to the United States. This panel will discuss the key issues that typically must be addressed by such planning, including timing of the commencement of U.S. federal and state tax residency, strategies that can be implemented pre-residency in order to minimize U.S. tax following an individual's residency start date, planning and reporting considerations for the period following his or her residency start date, and U.S. exit tax considerations.
Panelists:
Bryan Kelly – Counsel, Venable LLP