**HodgenLaw PC is providing CPE and CE for this session. The NYCPA is only hosting the event. To get your CPE certificate, you should contact HodgenLaw PC.** This exclusive hybrid CPE event is an International Tax Pros event hosted by HodgenLaw PC at the NYCPA/FAE Classroom, delivers critical updates and advanced planning strategies you can immediately apply to your practice. International Tax Pros members price: FREE with coupon code distributed in the forum. Use the coupon code at checkout.
Learning Objectives
- Upon completion of this session, you'll be able to:
- Understand the critical tests for determining "Covered Expatriate" status and strategies to avoid it.
- Understand how the Internal Revenue Code classifies foreign trusts, so you can advise trustees and beneficiaries of the U.S. tax consequences.
- Analyze the Act’s significant modifications to the stock ownership attribution rules under IRC §318 and how they impact Form 5471 filing requirements.
Major Topics
AGENDA
2:00
- 3:00 PM
Pre-Expatriation Tax Planning to Minimize Exit Tax
Presenter: Debra Rudd, CPA (HodgenLaw PC, Pasadena, CA) Assisting clients with renouncing their U.S. citizenship or terminating long-term residency requires navigating the treacherous waters of the IRC §877A "exit tax." This session provides a strategic framework for advisors to help clients plan before they expatriate, potentially saving them from significant tax liabilities.
3:00
- 4:00 PM
Foreign Trusts: Navigating Reporting and Compliance Challenges
Presenter: Bruna Barbosa (Mayer Brown, New York, NY) The compliance and reporting regime for foreign trusts remains one of the most complex areas of international tax, with severe penalties for non-compliance. This session will provide a crucial update on the current enforcement environment, recent developments, and best practices for ensuring your clients meet their obligations.
4:00
- 5:00 PM
Form 5471 After the One Big Beautiful Bill Act
Presenter: Philip D. W. Hodgen (HodgenLaw PC, Pasadena, CA) The "One Big Beautiful Bill Act" (H.R. 7024) introduces sweeping changes for international tax compliance, with Form 5471 directly in its crosshairs. While most changes are effective for tax years beginning in 2026, proactive planning is essential. This session will translate the new legislation into actionable steps for your practice.