In recent months, several seemingly unrelated developments in U.S. law and policy have begun to converge in a way that should capture the attention of tax professionals, immigration lawyers, and globally mobile individuals. On one front, the Department of Justice continues to press denaturalization cases against U.S. citizens who obtained their status by fraud or … Continue reading USCIS Update: Citizenship, Denaturalization, Tax Compliance, Moral Character
Category: NRAs Nonresident Aliens
Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist
Many non-Americans underestimate just how easily time spent in the United States can transform them into U.S. taxpayers. Under American tax law, you don’t need a U.S. passport or green card to face very significant IRS tax obligations. Simply spending enough days on U.S. soil may result in being classified as a “resident alien.” That … Continue reading Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist
U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card
Imagine over the years that you’ve built a nest egg in a U.S. Individual Retirement Account, Roth IRA, or Simplified Employee Pension IRA. This is a common scenario for many U.S. citizens and green card holders while working in the United States. In a scenario that is becoming increasingly more common, imagine that after years … Continue reading U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card
Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC
For some time, foreigners have been drawn to the U.S. real estate market due to its stability, potential for appreciation, and the reliable legal framework in America. A frequently used investment vehicle is a single-member limited liability company created under the laws of a U.S. state. A SMLLC offers liability protection and flexibility. The U.S. … Continue reading Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC
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
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
Giving Up Citizenship Or Green Card: Harsh Tax On Social Security
A portion of an individual’s U.S. Social Security retirement, survivors, or disability benefits may be subject to U.S. income tax, regardless if the individual is a U.S. or non-U.S. person. Before delving into the details about tax on Social Security, it is helpful to understand the different nomenclature when it comes to certain benefits. Social … Continue reading Giving Up Citizenship Or Green Card: Harsh Tax On Social Security
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
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
WEBINAR Expatriation & U.S. Tax Implications: Navigating Green Card (LTR) & Citizenship Relinquishment with IRS Final Section 2801 Transfer Tax Updates
If you are a US citizen or green card holder thinking about keeping or giving up your US status, tax professional, tax advisor, immigration consultant, enrolled agent, certified public accountant, family office, wealth advisor or wealth planner you should definitely attend this webinar. If you cannot attend, other options to obtain the webinar are available … Continue reading WEBINAR Expatriation & U.S. Tax Implications: Navigating Green Card (LTR) & Citizenship Relinquishment with IRS Final Section 2801 Transfer Tax Updates








