Multinational individuals will most often focus on income tax consequences of multinational activities; this approach risks minimization of transfer tax consequences. Non-resident individuals directly owning United States–situated assets face statutory exposure to United States transfer taxes. Given minimal exclusion amounts ($60,000 for estate tax purposes) and tax rates quickly reaching 40%, exposures in this context are enormous.

This program will cover the classification of individuals for transfer tax purposes and the scope of assets to which United States transfer taxes are applicable. The program will then discuss tax assessment, categories of exempt assets, and estate and gift tax treaty interplay with statutory rules.

Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars.

Learning Objectives: 

• Determine the classification of individuals for transfer tax purposes

• Identify the scope of assets to which United States transfer taxes are applicable

• Recall the tax assessment, categories of exempt assets, and estate and gift tax treaty interplay with statutory rules