Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA

Over my many years of international tax practice, I regularly come across the loving foreign parent (or relative) with a child (or other relation) residing in the United States. The individual may be studying there or living there and pursuing the American dream - starting a business or perhaps buying a home. He or she … Continue reading Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA →

Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship

Curious about what it means from a US tax perspective if you give up your green card or US citizenship? You really should know BEFORE you take the plunge and apply for that green card or obtain US citizenship. Tax pro's -- Want to expand your client reach by advising and planning with confidence about “expatriation”? … Continue reading Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship →

US Residency “First Year Election” and FBAR – The Devil is in the Details

Recently, I presented a webinar for tax pro’s earning CPE credits; the topic involved our favorite character, Mr. FBAR. The FBAR, Form 114, is more formally known as the Report of Foreign Bank and Financial Accounts. The webinar will be available soon as a CPE credit "self-study" program. Send me an email if you wish … Continue reading US Residency “First Year Election” and FBAR – The Devil is in the Details →

FBAR Traps: International Couples, Powers of Attorney

Meet the Zuhovitzky’s, the quintessential international couple: Jonathan (a naturalized US citizen and Israeli citizen living in Germany) and Esther (an Austrian and Israeli citizen who was never a US citizen or resident). I blogged about them and the IRS’ aggressive stance on asserting so-called FBAR penalties against Jonathan for having a power of attorney … Continue reading FBAR Traps: International Couples, Powers of Attorney →

Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

Last week's blog post looked at one way that a non-US citizen can become subject to US income tax on his or her worldwide income - simply by getting a US green card. Today's post looks at the other way one can fall into the US tax trap. “Substantial Presence” in the US An individual … Continue reading Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income? →

Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

US “residents” are subject to tax on income derived from all sources. That means they are subject to tax on their worldwide income regardless of the source of that income. So, for example, dividends earned from a French company are taxable, as is gain on the sale of rental property located in Hong Kong; prize money won … Continue reading Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income? →

Personal Liability for Tax – Estate Executor for a Non-US Decedent …. “Accidental” Executors Included!

My recent blog post covering the Federal Transfer Certificate generated various questions about the US estate tax for foreign individuals who die owning US properties. US Estate Tax - Overview Briefly, the US estate tax is a “transfer tax” and not an “income” tax. This transfer tax is asserted against the estate of the individual … Continue reading Personal Liability for Tax – Estate Executor for a Non-US Decedent …. “Accidental” Executors Included! →

The Federal Transfer Certificate: What Foreign Investors Into the USA Need to Know

Individuals living outside of the US who inherit a US asset from a foreigner may be in for some surprises. If the decedent is an individual who is treated as a nonresident alien individual (NRA) for US estate tax purposes, his heirs often have a difficult time obtaining actual title to the US asset they … Continue reading The Federal Transfer Certificate: What Foreign Investors Into the USA Need to Know →

IRS Tells You if You are Married and to Who! Yes, IRS has Rules For That!

An interesting case was recently decided. I blog about it today to warn those who marry or divorce in a foreign country about the US tax complications that can arise. It’s an area fraught with pitfalls and can impact the couple in many ways, including of course, their US tax planning. Let’s have a brief … Continue reading IRS Tells You if You are Married and to Who! Yes, IRS has Rules For That! →

All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It

Under current law, limited partners who materially participate in a partnership's business are not subject to self-employment tax. Members of an S corporation who materially participate in the S corporation's business are subject to self-employment tax only on "reasonable compensation" received in their capacity as an “employee”. These individuals are also exempt from the 3.8% … Continue reading All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It →