Category: Foreign Gifts or Bequests Foreign Trusts and Estates

Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship

On December 1, 2025, Senator Bernie Moreno (R-OH) introduced the Exclusive Citizenship Act of 2025. The bill would prohibit any person from simultaneously holding U.S. citizenship and citizenship of another country. The major provisions include: An effective date 180 days after enactment. The requirement that existing dual citizens would have one year to renounce all … Continue reading Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship →

Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory

In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory →

Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!

Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews! →

Executor Beware: Personal Liability for Unpaid Estate Tax and More

Serving as the executor of an estate is not just an administrative duty. It involves significant legal responsibilities, particularly when it comes to ensuring that all tax obligations of the deceased are properly addressed.  Executors must locate the estate’s assets, assess debts and liabilities, and make distributions to beneficiaries. Critically, they must do all this … Continue reading Executor Beware: Personal Liability for Unpaid Estate Tax and More →

Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules

When it comes to estate planning, how you hold property with others can have significant tax implications after you have passed on.  Internal Revenue Code Section 2040 governs how joint ownership of property with right of survivorship is treated for federal estate tax purposes.  The rules can catch even the most astute investors off guard. … Continue reading Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules →

40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”

Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025.  It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates” →

BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead

IRS literally just finalized the Code Section 2801 regulations on January 10.  These long-awaited final regulations concern gifts and bequests received by a U.S. person from foreign persons who were former U.S. citizens or green card holders who qualified as "long term residents" and were "covered expatriates" at the time of giving up their U.S. … Continue reading BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead →

Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons →

Cross-Border Transactions: Foreign Laws And U.S. Tax In A Borderless World

In today’s interconnected world, borders blur while regulations multiply. Families span continents, careers pivot across countries, and even currencies like Bitcoin redefine value. Meanwhile, the U.S. tax system casts an ever-wider net, taxing its citizens on worldwide income regardless of where they reside. Through measures like the Foreign Account Tax Compliance Act, the U.S. government … Continue reading Cross-Border Transactions: Foreign Laws And U.S. Tax In A Borderless World →

Late Form 3520 Foreign Gifts And Bequests, Good News From IRS

The IRS Commissioner Danny Werfel announced some good news for taxpayers at the end of October 2024. The IRS has ended its practice of automatically assessing penalties when a taxpayer voluntarily submits a late Form 3520, Part IV. This form deals with the obligation of U.S. persons to report to the IRS the receipt of … Continue reading Late Form 3520 Foreign Gifts And Bequests, Good News From IRS →