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 →

U.S. Tax – Think Carefully Before You Get (Or Keep) A Green Card

My article copied below, first appeared on Forbes June 19, 2024 – link here. It explains the important U.S. tax rules to know before getting (or keeping) a green card. Unfortunately, the U.S. government never explains these rules as part of the green card application process! In all my years of tax practice, I have … Continue reading U.S. Tax – Think Carefully Before You Get (Or Keep) A Green Card →

No U.S. Tax Honeymoon When Americans Marry Non-U.S. Citizens

My article copied below, first appeared on Forbes May 11, 2024 – link here. It provides some important tax tips for those in a US/non-US citizen mixed marriage! Follow me on Forbes for easy to understand US international tax coverage. I’d loved to be your “go-to” person when it comes to US tax issues impacting Americans … Continue reading No U.S. Tax Honeymoon When Americans Marry Non-U.S. Citizens →

U.S. Tax-Savvy Gifting By Foreigners To U.S. Persons

My article copied below, first appeared on Forbes May 11, 2024 - link here. Follow me on Forbes for easy to understand US international tax coverage. I'd loved to be your "go-to" person when it comes to US tax issues impacting Americans abroad or foreign persons with any US connection. The US always finds a … Continue reading U.S. Tax-Savvy Gifting By Foreigners To U.S. Persons →

Death Of The American Abroad: Untangling U.S. Tax Across Borders

Many 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 22, 2024 here. In our global society, more and more Americans are living and working overseas. This inevitably … Continue reading Death Of The American Abroad: Untangling U.S. Tax Across Borders →

Accidental Americans Learning They Are Citizens Face A Tax Dilemma

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 9, here. Don't miss out on my informative and easy-to-understand US tax content - Follow me on … Continue reading Accidental Americans Learning They Are Citizens Face A Tax Dilemma →

How do Estate Tax Treaties Work? They Don’t if the Decedent is a US Citizen or Domiciliary

My recent blog posts here, here and here have been examining the US estate tax and its impact on foreign investors in the US. The posts explored estate tax basics, the concepts of “domicile”, ”situs” of assets, the troublesome Federal Transfer Certificate and the paltry estate tax exemption of USD60,000 given to non-US non-domiciliaries for … Continue reading How do Estate Tax Treaties Work? They Don’t if the Decedent is a US Citizen or Domiciliary →

US Estate Tax: Location of Assets, More “Situs” Rules

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 →

US Estate Tax – What is “Situs”? Location of Assets Makes a World of Difference

My recent and upcoming blog posts are examining the US estate tax and how it often comes as an unwelcome surprise to the foreign investor in the US and to the foreign heirs when the investor passes away. The family is often left to clean up the mess if the investor has not properly planned … Continue reading US Estate Tax – What is “Situs”? Location of Assets Makes a World of Difference →

The Real World: When Foreigners Die Owning US Assets – Estate Tax, Federal Transfer Certificate and Related Troubles

My recent blog posts (e.g. here, and here) emphasized how important it is for Americans who are investing in foreign (non-US) assets to understand the US tax consequences of making that investment. Far too often I have seen individuals invest substantial amounts of money without knowing the tax impact of that infusion of hard-earned cash. … Continue reading The Real World: When Foreigners Die Owning US Assets – Estate Tax, Federal Transfer Certificate and Related Troubles →