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State and local tax issues are complex for individuals and entities subject to them, with assorted state-specific rules creating added tax consequences (both from a tax and compliance perspective). A foundational consideration for state and local taxes is where the ability to tax exists for a state—or city.
Learning Objectives:
- Determine the nexus of jurisdiction to tax—looking to a taxpayer's residence/domicile and assorted income sourcing considerations
- Identify special state-specific rules that will be detailed, such as California's residence provisions/standards
Patrick McCormick, JD, LLM
McCormick Tax, P.C.
Principal Attorney
pjm@mccormicktax.com
(215) 630-0861
Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.
Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.
Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.
Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
About Our Presenter
Our firm covers every aspect of United States international tax, trusts, and estates rules; we also assist our clients on more domestic-oriented United States tax needs. We work directly with clients; we also serve as “outsourced international tax counsel” for accounting, law, and advisory firms around the world. In that role, we assist wherever beneficial with those firms’ client needs in the international tax context, allowing those firms to hang onto clients/continue to work with those clients rather than losing them to firms with internal international tax teams. Our firm’s independent status gives us enormous flexibility in how we structure representations, ensuring we can serve in optimal fashion for whatever client needs arise.
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