With clients’ international travel plans destroyed by the pandemic and a changing landscape for personal and business planning, we all must stay current on the associated threats and opportunities to ourselves and our clients. In this webinar, we will explore how to inform, protect, and defend clients with respect to current and future international tax and estate planning.

Learning Objectives:

• Identify COVID-19 travel restrictions that can have “unintentional” consequences to U.S. taxpayers including current U.S. income tax residence law, the initial IRS reaction, the potential use of income tax treaty benefits, the effect on domicile, and remaining issues and planning alternatives


• Define IRS COVID-19 FAQs on U.S. Trade or Business and U.S. Permanent Establishment issues


• Recognize recent IRS guidance on filing Form 8858 for single-member foreign eligible entities and foreign branches and claiming the foreign earned income exclusion for U.S. persons that had to return to the United States


• Determine what happens if Congress reinstates IRC §958(b)(4) to again prevent “downward attribution,” and thus avoid unexpected U.S. shareholders of controlled foreign corporations


• Recall International compliance


• Define expatriation—the ultimate tax plan