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Structuring United States Investments by Foreign Taxpayers


This webinar was previously offered for 1 hour and has expanded to 1.5 hours
Cost Free
Presentation Length 1.5 hours

Recorded DateOctober 2, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The United States imposes a multitude of tax requirements on United States taxpayers with foreign investments, whether through information reporting requirements or, in the case of foreign corporations, immediate inclusions for what otherwise would be deferred income.  Rather curiously by juxtaposition, foreign taxpayers making investments in the United States often find favorable tax provisions, including exemptions from tax for many capital gains items.  It is critical, however, to properly structure United States investments by foreign taxpayers, looking both at relevant considerations and common techniques.

Learning Objectives:

  • Recognize Effectively Connected Income (ECI)

  • Recognize the basic structure of US income tax treaties

  • Recall how foreign trusts are taxed

  • Recognize common ownership structures

Not logged

Patrick is a partner with Culhane Meadows, a national law firm with a prominent practice in the international area.  Patrick practices exclusively in the area of international taxation.  He has extensive experience in handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties.  Patrick regularly works with advisors both in the United States and abroad to assist with international tax issues faced by their clients.

Patrick is a prolific contributor to a multitude of international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPA Academy on assorted international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and a LL.M. from New York University School of Law.  His bar admissions include Pennsylvania, Florida, New Jersey and Georgia.

Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication, named Patrick Estate Planning Lawyer of the Year (United States) for both 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.

About Our Presenter

Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.