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 – 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 →

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 →

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 →

Rich Americans…. Time to Wake Up!

Rich Americans (or foreigners with US assets), it's time to wake up and smell the coffee! Why? I am seeing more and more individuals with influence pushing for a change in the US tax laws so that wealth inequality becomes a thing of the past. Whether you agree with this position is not the point … Continue reading Rich Americans…. Time to Wake Up! →

Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now

The US gift tax is a tax imposed on the transfer of property by way of gift. The giver of the gift (the donor) is the party who must pay the tax. Generally, any transfer to an individual without receiving something of equal value in return (measured in money or money's worth) is treated as … Continue reading Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now →

D is for “Domicile”, Don’t Disregard!

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! →

All the Fun Rules — US Estate Tax for Nonresident Alien Individuals

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 →