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 →

Can Trump Revive The Revenge Tax By Executive Order ? OECD Delays Test G7 Deal

On May 22, as the House of Representatives passed H.R. 1—the "One Big Beautiful Bill Act" (OBBBA)—by a 215-214 margin, I outlined the implications of Section 112029 of H.R.1 in my earlier Forbes article. The provision, "Enforcement of Remedies Against Unfair Foreign Taxes,” would have added a new Section 899 to the Internal Revenue Code. As … Continue reading Can Trump Revive The Revenge Tax By Executive Order ? OECD Delays Test G7 Deal →

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 →

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 →

Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues

Purchasing or owning real estate property overseas can be an exciting investment opportunity, but for U.S. persons, it comes with significant tax and reporting obligations. Foreign persons becoming U.S. tax residents (e.g., obtaining a green card) may already own overseas properties and should be aware of the U.S. tax issues they will face at the … Continue reading Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues →

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 →

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 →