This course provides a rigorous, practice-oriented overview of U.S. federal tax law as it applies to non-resident individuals and foreign entities with U.S. income, investments, or operations. Through interactive simulations and applied legal exercises, the course equips legal and tax professionals with the tools to identify tax residency status, evaluate income sourcing rules, apply applicable treaty benefits, and manage compliance obligations for non-residents.
Participants will gain hands-on experience with U.S. withholding regimes, FIRPTA, business income versus fixed and determinable income distinctions, estate tax exposure, and international information reporting. Special emphasis will be placed on advising foreign clients entering the U.S. market and structuring investments to optimize tax efficiency and compliance.
Course Objectives
By the end of this course, participants will be able to:
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Analyze and determine tax residency status under U.S. law.
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Apply U.S. source income rules for investment, services, and real estate income.
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Navigate the dual tax regime: FDAP vs. ECI (Effectively Connected Income).
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Interpret and apply tax treaties to reduce withholding obligations.
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Advise clients on FIRPTA, U.S. estate/gift tax exposure, and ownership structuring.
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Prepare clients for compliance obligations, including Forms W-8BEN, 1040NR, and 1120-F.
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Structure inbound investments to mitigate tax and regulatory risk.
