What you need to know now about the taxation of US expats
Please note that sessions will run from 11am-1pm, Toronto time and 4-6pm, London time
Session 1: 9 February
Federal & State Tax Update: Alex Jones, Frank Hirth, London
Session 2: 10 February
A. Citizenship taxation - a regulatory fix; Tax residency - dealing with the FATCA/CRS letter: John Richardson, Citizenship Solutions, Toronto
B. Reporting requirements for foreign retirement plans after Rev. Proc. 2020-17: Max Reed, Polaris Tax, Vancouver
Session 3: 16 February
A. Dying with UK Assets: Peter Megoudis, Trowbridge, Toronto; Lisa Gray, Blick Rothenberg, London
B. The US provisions on cryptocurrencies: Glenn Snow, Frank Hirth, London
Session 4: 17 February
A. Non-residents investing in LLCs: Alex Jones, Frank Hirth, London; Peter Megoudis, Trowbridge, Toronto
B. Expatriation and the covered expatriate: John Richardson, Citizenship Solutions, Toronto
Session 5: 23 February
A. The generational transfer of wealth and the future of the estate tax exemption: Monte Silver, Silver Law, Herzelia Pituach
B. GILTI update: Alex Straight, Blick Rothenberg
Session 6: 24 February
A. CFC distributions: Follow the PTEP - Ray Kinoshita, Grant Thornton
B. The Biden Administration tax plans – what do we know and what do we expect? John Richardson, Citizenship Solutions, Toronto; Stuart Gibson, Washington DC; Elena Hanson, Oakville; Ray Kinoshita, Grant Thornton, Toronto
Sessions may be added, or the order changed, subject to speaker availability
Hear from our top experts on US tax
Alex Jones is a US and UK personal tax advisor with 30 years’ experience of providing complex planning and assistance to high net worth individuals.
He returned to Frank Hirth in August 2017 after an absence of 16 years, the last 10 of which he spent in a leadership role in Deloitte’s US/UK High Net Worth Practice in the UK.
Alex specialises in clients connected to the funds industry such as investment professionals, as well as business owners and entrepreneurs. He advises on the US/UK interactions on personal income, capital and social security, estate and Inheritance taxes and the use of trusts.
He is particularly noted in respect of the application of the UK/US tax treaty, including pension issues, the UK treatment of LLC interests, carried interests and FATCA.
Alex is licensed to practice before the Internal Revenue Service in the US (Enrolled Agent), sits on the British American Business Inc (BABi) Tax Forum and has been a very regular speaker at the US Professionals Association and its predecessor organisations over the last 20 years.
John Richardson is a Toronto-based lawyer, a member of the Bar of Ontario. He has a niche practice focusing specifically on the problems of US citizens and Green Card holders who (in addition to being subject to US worldwide taxation) bear the burdens of being tax residents of other countries. In other words, they must successfully navigate and prosper in accordance with he tax and regulatory regimes of two countries. A large part of his work includes assisting individuals with the relinquishment of U.S. citizenship and Green Card abandonment.
He writes for numerous blogs, maintains a podcast and speaks regularly on all matters related to citizenship, taxation and citizenship-based taxation. He is a contributing editor - on Tax Residency - to the Lexis Nexis treatise on FATCA and CRS.
Glenn Snow is a dual US and UK tax handler, providing a range of compliance and advisory services for a diverse client portfolio which includes high net worth individuals and expatriates.
Glenn has extensive knowledge of both UK and US tax reporting and compliance regulations, and has established a specialist interest in US expatriation for both US citizens and Green Card holders. He has worked in this fast growing and complex area since first joining the firm, over 10 years ago and is now a recognised expert.
Glenn spent 2013 to 2015 on secondment to Frank Hirth's New York office, and has been recognised in e-privateclient’s top 35 under 35 award for two consecutive years in both 2016 and 2017 in recognition of his commitment to the firm and his clients.
Glenn was promoted to Associate Director in 2018. He is a member of the Association of Taxation Technicians (ATT) and a US Enrolled Agent (EA).
Max Reed is a Cross-Border Tax Lawyer and the founding partner of the firm. He solves tax problems that span both sides of the Canada-US border including: advising corporations on the US tax implications of cross-border transactions and initial public offerings as well as streamlining cross-border business operations; developing estate and tax plans that work on both sides of the border; advising Canadian investment funds on investments into the United States and receiving investments from US taxpayers.
Max is the co-author (with Dick Pound of Stikeman Elliot) of A Tax Guide for American Citizens in Canada, as well as over 20 technical and plain language articles on a wide range of cross-border tax topics. Max has developed a number of novel solutions to common cross-border tax problems.
Recognized for his expertise, Max is often invited to speak at conferences and seminars for tax professionals and the general public in both the US and Canada. He was invited to testify before the Canadian House of Commons Finance Committee on the impact of US tax law on Canadians.
Prior to founding Polaris Tax Counsel, Max worked at White & Case LLP, an international law firm in New York City where he provided US tax advice to individuals, corporations, and foreign states. He clerked at the Canadian Federal Court of Appeal for the Honorable Karen Sharlow where he assisted with resolving a number of complex Canadian tax cases.
He holds a BA and two law degrees from McGill University, where he won a number of academic and leadership awards. He is admitted to the bars of BC and New York as well as to practice before the US Tax Court and the US Court of Federal Claims.
Trowbridge Professional Corporation
Peter Megoudis provides a wide variety of cross-border (US and Canadian) tax services, including advising High Net Worth clients on corporate, trust, and personal structuring of their businesses, trust and estate planning, and trust and personal tax filings and compliance. He also advises individuals on tax planning and compliance implications of leaving or entering Canada, or expatriating from, or leaving, the US; as well as assisting them in US or Canadian Voluntary Disclosure applications. He also consults with both companies and executives on designing deferred compensation plans, and determining compliance with US and Canadian compensation rules.
He has over 20 years of experience as a Partner in a big four firm in their Global Employer Services Group and the cross-border tax field, and has published extensively on both HNW and compensation areas, and is a frequent speaker at conferences and forums.
Lisa Gray is a senior tax manager at Blick Rothenberg, who specialises in US / UK tax advisory and compliance services. She started her career in expatriate tax compliance at PricewaterhouseCoopers and later moved firms to take on a private client role dealing with both US and UK cross border issues. She now sits within the Trust and Family Wealth team within Blick Rothenberg and provides US and UK advisory and compliance services to trustees and beneficiaries in respect of their interests in trusts; both US domestic and non-US trusts. She also provides services to multi generation families with US estate and UK inheritance tax considerations.
Silver & Co.
Monte Silver specialises in providing U.S. tax counsel to entities and individuals on issues of tax, disclosure, or estate planning matters, as well as to non-U.S. persons with business or investment matters in the U.S. Monte has 20 years' experience in U.S. tax planning for U.S. and non-U.S. persons.
Earlier in his career he had experience in the IRS Estate & Gift Tax Division and the U.S. Tax Court. Monte has a special interest in U.S. Federal tax advocacy.
International Bureau of Fiscal Documentation
Stuart Gibson joined IBFD as Chief Editor, US in December 2019 after a 30-year career as a senior litigator in the Tax Division of the US Department of Justice (and before that, seven years at the IRS). There he handled high-profile matters such as the first tax shelter promoter summons cases, “Son of BOSS” tax shelter trials, and successful efforts to enforce “John Doe” summonses against large foreign banks. (If you ask, he will tell you he considers himself the illegitimate uncle of FATCA.)
After leaving the government, Stuart wrote the chapter on IRS summonses for Saltzman & Book on IRS Practice & Procedure., leading to nearly three years as editor of Tax Notes International. Stuart then worked for about 18 months as counsel at the Chicago-based law firm Schiff Hardin LLP, where he successfully represented taxpayers in disputes with the IRS, before returning to tax publishing in early 2019, managing the international tax team at Bloomberg Tax, then joining IBFD as Chief Editor, US, and is now Chief Editor, Global News and US, where he runs the newsroom and contributes to IBFD’s US content.
Hanson Crossborder Tax
Elena Hanson is a Managing Director of Hanson Crossborder Tax Inc, a private international tax advisory company which she founded in 2012.
Elena assists US, Canadian and international private clients, businesses and the institutions that service them on cross-border taxation issues, investment structuring, and trust and estate planning. She works with Canadian and non-US resident clients and entities on structuring US inbound investments to minimize federal and state income tax exposure. She advises US clients on tax aspects of foreign investments, including anti-deferral rules, entity classification issues and reporting requirements for foreign entities and trusts. Her work in that area also encompasses Canadian and US pre-immigration, departure taxation rules, and expatriation planning, cross-border compensation and employment tax issues and corporate structuring for foreign companies setting up US or Canadian operations. She has extensive experience in crossborder estate and trust tax planning and compliance and crossborder separation and divorces.
She is licensed as a Certified Public Accountant, holds a Master’s in Taxation from Golden Gate University, California, USA, Bachelor of Science in Business Administration – Accounting from Marian University, Wisconsin, USA.
Ray Kinoshita has been a tax practitioner since 1983, specialising for 15 years in Canada-US cross-border tax matters, including structuring of cross-border investments and planning for tax-efficient financing in both directions, both for corporations and for individuals. During a two-year secondment in Europe, he gained a greater global perspective on Canadian and US international tax considerations.
From 1998 until 2014 he focused primarily on US tax matters for Canadian businesses investing in and sending employees to the United States and for US businesses investing in and sending employees to Canada, before re-focusing on Canada-US personal tax matters. At present, he is consulting on both US corporate and US personal tax issues for residents of Canada with Grant Thornton, from which he is now retired as partner.
He is much in demand as a speaker and writer.
Alex Straight is a partner in the Private Client department at Blick Rothenberg and has been practising US and UK tax since 2007. He works primarily with entrepreneurs and owner-managed businesses assisting with their US and UK tax considerations. He covers a wide range of businesses and individuals ensuring that his clients’ personal and business tax considerations are aligned. This includes US reporting and tax advice in relation to international business structures and cross-border business advice. Alex is a UK Chartered Tax Adviser and an agent enrolled to practise in front of the Internal Revenue Service.
Pricing and booking
For participants in Canada: CAD$1000 plus HST
For participants in the UK and elsewhere: £600 plus applicable VAT
Payment can be made by bank transfer or Visa/MasterCard or in Canada by email transfer. Details will be shown on the invoice.
CE, CPD, CPE credits
A total of 12 credit hours will be available for this event. CE credits for enrolled agents are automatically given.
Our partner in Canada
The conference is offered in association with CPD Programs, who will handle all payments for Canadian participants.
Booking terms and cancellation policy