Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
As some of my readers know, I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 14, 2024 here. Don't miss out on my informative and easy-to-understand US tax content - Follow me … Continue reading Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency
As most of my readers know the Corporate Transparency Act (CTA) requires US entities (including for example, US LLCs, corporations, partnerships), and many foreign entities including those that register to do business in a state, to disclose to FinCEN of the Treasury Department, the identity of their beneficial owners. Information to be provided: name, date … Continue reading Corporate Transparency Act: BEWARE! The Scammers have Already Arrived!
My earlier blog post discussed National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.), the Northern District Court of Alabama decision that enjoined all relevant US government agencies from enforcing the Corporate Transparency Act (CTA). That post raised the issue: exactly who is entitled to the benefits of this injunction? Well, let's look carefully … Continue reading Corporate Transparency Act – Unconstitutional, But Keep Reporting!
With this surprising court decision issued March 1, 2024, millions of overwhelmed small business owners can now take a breather from scouring FinCEN’s website and go back to running their businesses. The Northern District Court of Alabama has enjoined all relevant US government agencies from enforcing the Corporate Transparency Act (CTA). The UNITED STATES DISTRICT … Continue reading Corporate Transparency Act Declared Unconstitutional
Part I of this blog post examined some of the rules regarding the US estate tax and how it applies to non-US persons (noncitizen/nonresident - based on the concept of "domicile"). Unfortunately, the US estate tax often catches the non-US citizen non-domiciliary's family by surprise and when it does, it bites hard. Remember, the non-US citizen … Continue reading US Estate Tax: Location of Assets, More “Situs” Rules
An earlier blog post explained how easy it is for the foreign person to fall into some nasty US tax traps when entering a foreign partnership with a US person. Even if that foreigner never sets foot in America and works solely from the foreign location, he can end up paying US taxes. In addition, … Continue reading Foreign Partnerships with a US Partner? Some Planning Ideas
Last week I blogged about the US income tax issues that plague a US partnership when it has a foreign partner. That post showed things can get ugly when a US partnership has a foreign partner. The post got a lot of views and feedback so it is evidently a topic of interest. I thought … Continue reading Tax Things Get Ugly for Foreigners When a Foreign Partnership has a US Partner
Part 1 of this blog post introduced readers to some of the issues surrounding US taxation of foreign persons and discussed the pitfalls of tax ignorance. This 2-part series identifies areas of potential US tax exposure for foreign nationals and examines the questions the foreign person and his advisors should be asking before taking a … Continue reading Breathing American Air – Hazardous to your Wealth? (Part II)
Foreigner asks: “Can I breathe American air without being subject to US tax?” The answer to that question is a big, fat MAYBE. For starters, it depends how long you were in the US breathing that air. While the question might sound funny, there is absolute truth in the answer. It amazes me how many … Continue reading Breathing American Air – Hazardous to your Wealth? (Part I)
Part I of this blog post examined the US tax issues faced by the Duke of Sussex who moved with Duchess Meghan to Los Angeles in March 2020. Given the significant number of days of physical presence in America, Prince Harry has most likely already met the "substantial presence test" and is being taxed the … Continue reading Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?
Virginia - US TAX TALK 