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! →

5 U.S. Estate Tax Surprises For Nonresident Alien Investors

Foreign investors can win big with United States investments. While holding U.S. assets can be lucrative, the U.S. estate tax regime is complex and often misunderstood by nonresident alien investors. NRAs, those who are neither U.S. citizens nor residents for estate tax purposes, are often very surprised when they learn of the challenges imposed by the … Continue reading 5 U.S. Estate Tax Surprises For Nonresident Alien Investors →

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 →

Leaked Memo Includes Major Tax Reform And Impacts U.S. Persons Abroad

A recently leaked memorandum discussed by JD Supra, has revealed potential tax reform under discussion in the U.S. House of Representatives. These share some key elements with President Donald Trump’s tax reform proposals, reflecting a coordinated effort to implement significant change. The leaked information contains changes that could reshape the tax obligations of U.S. persons … Continue reading Leaked Memo Includes Major Tax Reform And Impacts U.S. Persons Abroad →

Proposed Death Tax Repeal: Foreign Investors Win, Covered Expats Don’t

A new legislative effort, which started last year as House Bill 7035 was reintroduced in January 2025 by Representative Randy Feenstra, R-Iowa. The "Death Tax Repeal Act," seeks to repeal the U.S. estate tax (often called the Death Tax) and the generation-skipping transfer tax. If passed, the Death Tax Repeal Act would have far-reaching implications for wealthy … Continue reading Proposed Death Tax Repeal: Foreign Investors Win, Covered Expats Don’t →

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” →

U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens

Foreign investors with assets in the United States often encounter complex estate tax rules that can significantly impact taxation of their U.S. assets at death. If the individual is a non-resident, non-citizen of the U.S. (NRNC), the U.S. estate tax applies only to assets situated or deemed to be situated within the U.S. (for example, … Continue reading U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens →

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 →