This program provides an overview of the tax rules relevant in multinational compensation—income which is subject to either tax or withholding by multiple jurisdictions. Covered within this program will be basic sourcing rules for income and treaty modifications to default American rules for non-resident personal services taxation and options for American taxpayers to exclude foreign-sourced earned income through the foreign earned income exclusion. The program will also detail the special rules for multiyear compensation, i.e., compensation attributable to multiple years of work/numerous places of performance.
Learning Objectives:
- Recall an overview of the tax rules relevant to multinational compensation
- Identify sourcing rules for income as well as treaty modifications
- Recognize the special rules for multiyear compensation
Patrick McCormick, JD, LLM
Culhane Meadows, PLLC
Partner
pmccormick@cm.law
(215) 630-0861
Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience 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. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.
Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPAacademy.org on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law. His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.
Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.
About Our Presenter