Date: June 16 , 2025 

Time: 1pmET | 12pm CT | 11am MT | 10am PT

Duration: 120 Minutes

Description:

Expatriation from the United States carries some of the most intricate and consequential tax implications in international tax law. Failure to plan properly can result in significant financial burdens for individuals giving up U.S. citizenship or long-term green card status.

Recent developments—such as updates to IRS Form 8854 and the issuance of final regulations under Section 2801—have introduced new compliance obligations that affect both expatriates and U.S. recipients of their gifts and inheritances. Many are unaware that relinquishing their status without proper guidance may result in being classified as a “covered expatriate” (CE), triggering the exit tax and future transfer tax liabilities.

This comprehensive CE course, led by international tax expert Virginia La Torre Jeker, offers a deep dive into the U.S. expatriation tax regime. Topics include the exit tax, net worth and income tests, treaty tie-breaker considerations, and detailed IRS compliance requirements. Tax professionals will gain the tools needed to effectively advise clients on expatriation planning and avoid costly pitfalls.

With the IRS intensifying audits in this area, staying up to date on expatriation rules has never been more essential.

Key Topics Covered

• Latest IRS Updates on Expatriation Tax Rules
• Relinquishment of Green Cards: Legal and Tax Considerations
• Exit Tax Calculations and the Net Worth Test
• Covered Expatriate Status: Criteria, Exceptions, and Planning Opportunities
• Section 2801 Transfer Tax: Implications for U.S. Heirs and Beneficiaries

Learning Objectives

• Describe the various methods by which a U.S. citizen may expatriate and assess the associated tax risks.
• Explain how long-term green card holders can be classified as covered expatriates and the resulting tax consequences.
• Evaluate the role of treaty tie-breaker provisions for green card holders and identify potential risks n expatriation planning.
• Identify the criteria for covered expatriate status and apply strategic planning techniques to help clients avoid triggering it.
• Accurately calculate a client’s net worth for the Net Worth Test, including special considerations for married individuals.
• Interpret the final IRS regulations on the 40% transfer tax under Section 2801 and understand the broader expatriation tax framework under IRC Sections 877 and 877A.

Credits and Other information:

• Recommended CPE credit – 2.0
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 2 Hours

Who Will Benefit:

• CPA
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
• Financial planners

About Our Speaker

Virginia La Torre Jeker , J.D.
With 40 years of US tax and international experience, Virginia has been a member of the NYS Bar since 1984 and is admitted to practice before the United States Tax Court. Practicing US tax overseas since 1986, Virginia’s work has focused on clients throughout Europe, Asia and the Middle East. She provides expert insight into tax planning and compliance for American expats and foreign persons having any US connections.

Virginia has expertise in cross-border transactions and structuring, FATCA, regaining US tax compliance with previously unreported foreign income, assets or accounts, expatriation tax planning, and providing specialist advice for international families in numerous areas of US international tax.