Citizenship and Residence: Prerequisites to Extra Territorial Taxation

SKU: TAX4200

Idaho CLE
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About This Course

This comprehensive CLE course will examine the many jurisdictional bases for the imposition of tax on extra-territorial income. The course will focus on natural persons and the meanings that are typically ascribed to the variety of bases for the code.

The course will cover state statutes as well as some countries’, residence status for the purpose of tax treaties, dual residents, the planning for and acquisition of status, planning for and relinquishing status, expatriation, and the enforceability of departure tax.

The course will address both the theoretical and practical considerations involved and use illustrative examples to better clarify key areas.

Lecturer Bio

Fred Feingold, Esq.

Fred Feingold, is the senior partner of Feingold & Alpert, LLP, a New York based law firm that specializes in federal, state and local and international tax issues for diverse clientele, including large pools of institutional and private funds, public and privately traded companies, prominent individuals, entertainment groups and entities in connection with various aspects of the entertainment and related media businesses in which they operate.

He has advised regarding the structuring of numerous complex partnership arrangements, involving investment and trading partnerships, hedge, private equity and other investment funds, the activities of their management companies and investment matters pertaining to carried interest, and deferred management fees and the issuance of options, warrants, and other units in connection with such entities.

He also has been involved as lead tax counsel in connection with the resolution of numerous complex tax disputes at the audit, administrative appeals and U.S. tax court and New York administrative court levels involving domestic tax issues, residency and domicile issues, issues relating to source of income, excess compensation, transfer pricing adjustments, tax treaty issues as well in connection with the resolution of non-U.S. tax disputes in various countries.

Mr. Feingold has earned the peer recommended Martindale-Hubbell AV Preeminent Rating, the highest possible rating for an attorney for both ethical standards and legal ability. Mr. Feingold has served as co-editor of the Journal of Taxation's International Department and is an emeritus member of the Advisory Board of the New York University Institute of Taxation. Mr. Feingold has lectured to professional groups such as the Practising Law Institute, the International Fiscal Association, the International Bar Association, Centro Di Studi Bancari (Lugano) and the International Tax Institute among others concerning U.S. and international tax matters. He has authored numerous articles on various aspects of international tax matters.

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Citizenship and Residence: Prerequisites to Extra Territorial Taxation

Idaho CLEAccreditation Info

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About This Course

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