When a taxpayer is a “resident” of a State which imposes income tax, he has to pay State tax on worldwide income, not just the income earned from sources within that State. If a taxpayer is working and residing overseas for an indefinite period of time and may or may not return to the State … Continue reading State Income Taxes When Residing Overseas… They Hate to Let You Go!
Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one is a US person and they are impacted by application of a foreign country’s community property laws. You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!
Many non-US individuals come to me with questions concerning their liability for US taxes - income, gift, estate tax. I find there are some general misunderstandings - hardly surprising given the complexity of the US tax system. Let's review! Before we talk about foreign (non-US) individuals, let's be clear: US citizens are always treated as … Continue reading Foreign Nationals – Am I “Resident” for US Estate & Gift Tax Purposes?
Very few US Estate tax returns are actually filed by the estates of nonresident alien individuals. Statistics indicate that the amount of Estate Tax earned by the US Government on such returns is quite small. The cost of structuring to avoid the tax is probably of far greater magnitude than what is collected by the US … Continue reading All the Fun Rules — US Estate Tax for Nonresident Alien Individuals