Virtual

International Tax Series—Pre-Expatriation Tax Planning to Minimize Exit Tax

Date: Nov. 21, 2025

Time: 9 – 10 a.m. PT

CPE: 1

Overview

Every month, a new international tax topic. Join the Hodgen Law team live—fresh insights, straight from the source. This month, we’ll explore issues with pre-expatriation and tax planning.

This course takes a proactive look at pre-expatriation tax planning, highlighting strategies to reduce or avoid the exit tax burden. This session is packed with practical insights from understanding who qualifies as a “covered expatriate” to exploring asset restructuring, trust planning, and timing tactics. We’ll help you guide clients through the high-stakes expatriation process—smartly, legally, and with minimized tax consequences.

View all courses in this series.

Formerly named International Tax Lunch Series November 2025

Product Code
1000003992-132940
Credit Type
CPE: 1
CPE-Technical: 1
CTEC-TX: 1
IRS-TX: 1
MCLE LS-TX: 1
Intended Audience
CPAs, tax preparers and advisors who what to stay current on the latest developments on international tax issues.
NASBA Field of Study
Taxes
Level of Difficulty
Overview
Prerequisites
None
Advance Preparation
None

Learning Objectives

Define the criteria for “covered expatriate” status under Section 877A and explain its tax consequences.

Evaluate the impact of the exit tax, including how deemed gains are calculated and taxed at expatriation.

Apply strategies to restructure assets, reduce net worth, or transfer wealth before expatriation to minimize exit tax exposure legally.

Advise clients on the timing of expatriation and the documentation required for compliance.

Recognize the risks of aggressive planning and IRS scrutiny related to pre-expatriation gifting and offshore assets.

Assist in navigating complex scenarios involving pensions, deferred income, trusts, and family-owned businesses in a cross-border context.

Major Subjects

Overview of the Exit Tax Regime (IRC Section 877A)
Key Planning Considerations Before Expatriation
Asset Restructuring and Gifting Strategies
Compliance Checklist and Filing Requirements
Planning for Special Cases

Faculty

Philip D.W. Hodgen

Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand....

More about Philip D.W. Hodgen

International Tax Series—Pre-Expatriation Tax Planning to Minimize Exit Tax

Member

Nonmember

Overview

Product Code

Credit Type

Intended Audience

NASBA Field of Study

Level of Difficulty

Prerequisites

Advance Preparation

Learning Objectives

Major Subjects

Faculty