Expatriation and the Heirs of Covered Expatriates: Section 2801, Final Regulations and Form 708 in Practice
Join Paula Jones for a webinar discussing expatriation and the implications of Section 2801 regulations for U.S. heirs of covered expatriates. The session will cover planning strategies, tax obligations, and how to identify covered expatriates, along with practical examples and opportunities to mitigate tax exposure.
Speakers

Ashley Murphy, CFP® GFP Fellow, is a tri-citizen of the USA, Australia and the UK. Ashley is the founder and Principal of Arete Wealth Strategists Australia, a fee-only financial planning and investment management firm for Australian/American expatriates in the United States and Australia.
From 2014 - 2017, Ashley taught in the CFP programs at UC Berkeley Extension and Golden Gate University. He served as a Knowledge Circle host for the Financial Planning Association's International and Cross-Border Knowledge Circle (2017 - 2019), and is a regular conference speaker. He holds a Graduate Diploma in Financial Planning in Australia making him one of the few financial advisors qualified in multiple countries. Ashley has been quoted in the Wall Street Journal and profiled in Financial Advisor Magazine.
Ashley lives with his wife Eliza, and daughters Elise & Jasmine in Minneapolis, MN. He enjoys cycling, reading and world travel. He is a futurist with interests in architecture, renewable energy and demographics.

Jones Estate Group, Inc. serves clients in all aspects of international and domestic estate planning and estate and trust administration, business succession planning, family corporations and private charitable foundations. International estate matters include foreign account and asset compliance, residency determinations, expatriation planning and pre-immigration planning, foreign ownership of U.S. real estate, foreign non-grantor trusts and probate of U.S. assets owned by non-U.S. persons. Domestic estate matters include Wills, revocable trusts, powers of attorney healthcare declarations, trusts for minors, residuary/marital plans to minimize federal estate tax, dynasty trusts, irrevocable life insurance trusts and charitable planning, including private foundations, the administration of estates upon death and trust administration, including reformations, mergers, divisions and terminations, accounting and audits. Tax and Reporting matters include gift tax returns, federal estate tax, state inheritance and estate tax and federal and state fiduciary income tax returns and all U.S. reporting requirements for foreign accounts, assets and trusts.
About this webinar
This program will explore how the new Section 2801 regulations and Form 708 dictate planning for clients who expatriate and for the U.S. heirs who inherit from them. The session will explain the transfer tax regime on “covered gifts” and “covered bequests” from covered expatriates, outline tax and reporting obligations (including the new Form 708), and illustrate practical planning strategies and traps for U.S. beneficiaries.
By the end of the session, attendees should be able to:
- Identify who is a “covered expatriate” and how to avoid this characterization.
- Distinguish between covered gifts/bequests and non‑covered transfers under Section 2801.
- Explore new Form 708 and how the Section 2801 tax is calculated, including use of the annual exclusion and applicable rate.
- Apply the rules to common fact patterns involving U.S. heirs of expatriates, and identify planning opportunities to reduce or avoid Section 2801 exposure.
We hope you can join us!
FAQs
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