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The United States imposes a multitude of tax requirements on United States taxpayers with foreign investments, whether through information reporting requirements or, in the case of foreign corporations, immediate inclusions for what otherwise would be deferred income. Rather curiously by juxtaposition, foreign taxpayers making investments in the United States often find favorable tax provisions, including exemptions from the tax for many capital gains items. It is critical, however, to properly structure United States investments by foreign taxpayers, looking both at relevant considerations and common techniques.


  • Awareness of income tax rules relevant to non-resident aliens
  • Awareness of transfer tax rules relevant to non-resident aliens
  • Familiarity with non-tax considerations important to non-residents in U.S. asset ownership
  • Review of common ownership structures for non-resident investment
  • Analysis of ownership structures
  • Review of non-U.S. tax considerations

Practitioners should attend this training to learn about the tax rules relevant to non-residents – both from an income and transfer tax perspective. The program then applies these rules to evaluate the ownership structures most commonly used by non-residents for United States assets. 


  • Accountants
  • Attorneys
  • Financial advisors
  • Individuals who work with/are non-residents

Patrick J McCormick is a partner with Culhane Meadows, a United States law firm with prominent experience and specialty in the international realm. Patrick practices exclusively in the area of international taxation; he has extensive experience in handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. He regularly works conjunctively with advisors both in the United States and abroad to assist with international tax issues faced by their clients.

Patrick is a prolific contributor to a multitude of tax journals and legal publications, including Tax Notes, Law360, the Journal of Taxation, and Tax Notes International. He is an active speaker and panelist for national seminars and webinars, covering both macro-level international tax considerations and more specialized topics within the area. He holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law. 

Each year from 2016-2020, Patrick has been recognized by Super Lawyers as a Rising Star (an annual recognition given to a maximum of 2.5% of qualifying United States attorneys). Finance Monthly, a United Kingdom-based publication, has previously named Patrick their Estate Planning Lawyer of the Year for work completed with non-resident clients.

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