Tax and Immigration Planning and Compliance for High Net Worth Individuals Acquiring U.S. Citizenship, Green Cards and Expatriating - New York, NY

New York, NY
June 12, 2017

Price: $795


June 12, 2017


AMA Conference Center
1601 Broadway (at 48th and Broadway)
8th Floor
New York, NY 10019

Hotel accommodations are at your own discretion. AMA has negotiated preferred rates at the following hotels based upon availability. Please contact the hotels below directly and be sure to mention that you are an AMA conference attendee to secure your reservation and preferred rates.

Belvedere Hotel
319 West 48th Street
New York, NY 10036
(212) 245-7000

Crowne Plaza Manhattan
1605 Broadway
New York, NY 10019
(212) 977-4000



This one-day, introductory-level course with live group instruction will provide insight as to how the tax and immigration rules can be coordinated from a planning perspective and how to remediate both immigration and tax omissions.

Learn the answers to these important questions:

  • What are the pros and cons of different immigration visa categories?
  • Is my client an accidental U.S. citizen?
  • How do the immigration and tax rules correlate?
  • What is the difference if I am a U.S. resident under the “substantial presence” test or the “green card” test?
  • What do I do if I left the United States but did not turn in my green card?
  • What are the U.S. expatriation rules and how do they apply?
  • I am a noncompliant U.S. taxpayer; how do I voluntarily comply?
  • And more!

All paid attendees will receive their choice of the following Bloomberg BNA Portfolios:
U.S. Income Taxation of Nonresident Alien Individuals (Portfolio 907)
Immigration and Expatriation Law for the Estate Planner (Portfolio 806)

*One Portfolio per paid attendee. Quantities are limited.


7:30am  Registration and Continental Breakfast

8:15am  Welcome and Introduction

8:30am  Immigration Aspects of Citizenship, Green Cards and Expatriation

o US Immigration Planning for High Net Worth Clients
  • Non-Immigrant Visas
  • Immigrant Visas (“Green Cards”)
  • Planning

o US Citizenship
  • How Acquired
  • Accidental US Citizens
  • How to Terminate (what to consider besides taxes)
  • Planning

o Green Cards and the “Exit Tax”
  • How to Terminate
  • Four Immigration Options to Avoid “Exit Tax”
    o Fold
    o Hold
    o Downgrade
    o Upgrade

10:00 am  Refreshment Break

10:20  U.S. Taxation
o Taxation of US Citizens
  • US Income, Estate and Gift Taxation
  • Worldwide
  • Information Reporting

o Who is a US Tax Resident and Taxation
  • Definitions
  • Different Tests
    o Income Taxation
    o Estate and Gift Taxation
  • Income Taxation: Two Tests
  • Lawful Permanent Resident (“Green Card”)
    o Substantial Presence
    o Consequences of US Resident Income Taxation
    o Worldwide Taxation
    o Expatriation Provision applicable to long term resident

o Who is a Non-Resident Alien
  • Definition
  • Tax Regime
    o Income Tax
    o Estate and Gift Tax

o Who is a Resident under the Treaty Tie-Breaker Rules
  • What are these rules
  • Aliens Impacted
  • Application
  • Compliance

12:00 pm  Lunch

12:45 pm  Expatriation

o Who does it Cover
  • US Citizens
  • Long Term Residents
  • Historic Rules
  • Current Rules
    o Covered Expatriate
    o Exceptions
  • Income Tax Consequences
  • Estate and Gift Tax Consequences
  • Compliance
  • Planning
  • Special Problems
    o Non-Compliant
    o Certificate of Loss of Nationality

2:00 pm  U.S. Tax Compliance

o Compliance
  • Obligations of US Citizen and US Resident
  • Consequences of Non-Compliance
    o Income Tax
    o Expatriation
    o US Estate and Gift Tax
  • IRS Voluntary Compliance Initiatives
    o History
    o Current
    o OVDP
    o Streamlined Programs (Foreign and US)
    o Alternatives
    o Willfulness
    o Delinquent FBAR and International
    o Information Returns
    o What to do
    o How long will programs last

3:30 pm  Refreshment Break

3:45 pm  How US Government Obtains Information about Non-Compliant US Taxpayers
o Treaties
o Tax Information Exchange Agreements
o Whistleblowers
o John Doe Summons
o Informal Exchanges
o Future: Common Reporting Standard

4:30 pm Wrap up and Q&A
o Wrap up of Issues
o Where we are
o Planning
o Way forward



If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event.

Cancellations must be made in writing to more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at 800.372.1033, or e-mail



Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at

Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.



Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.