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

BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud

Roger Ver, an early bitcoin investor (from approximately 2011) also known as “Bitcoin Jesus,” was just arrested in Spain based on US criminal charges. According to the indictment filed February 15, 2024 but recently unsealed, Ver has been charged with mail fraud, tax evasion, and filing false tax returns. Ver was a former US citizen who … Continue reading BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud

Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency

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

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

Too Many Days in America?  The “Closer Connection Exception” May Save the Day (& the Tax Hit)

Most people have heard of it, but not many truly understand it.  I will hear a foreign individual proudly state he cannot be taxed by the US since he has no income from US sources and has not spent 183 days or more in the US in any calendar year. Therein lies the “misunderstanding” and … Continue reading Too Many Days in America?  The “Closer Connection Exception” May Save the Day (& the Tax Hit)

Tis the Season! Giving / Getting Gifts from a Foreign Entity?

Holidays are soon upon us, and many people will be making gifts to family and friends.  It is very common to make gifts of cash – typically sending funds from a bank account to the recipient’s account. When gifts are made by foreign persons to US persons, there are many US tax traps for both … Continue reading Tis the Season! Giving / Getting Gifts from a Foreign Entity?

Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024

Revenue Procedure 2023-34 was released by the IRS on November 9, 2023.   It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024