Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property
The endorsement of an elective residence-based taxation model by former IRS Commissioner Charles Rettig and former IRS Commissioner Counselor Tom Cullinan, covered in my earlier Forbes article, has sparked important discussions about fairness for Americans abroad. Their piece highlights the burdens of America’s citizenship-based tax system and calls for a shift to treat expats more … Continue reading Residence-Based Taxation: Social Security, Pensions And 30% Withholding
Many non-Americans underestimate just how easily time spent in the United States can transform them into U.S. taxpayers. Under American tax law, you don’t need a U.S. passport or green card to face very significant IRS tax obligations. Simply spending enough days on U.S. soil may result in being classified as a “resident alien.” That … Continue reading Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist
Imagine over the years that you’ve built a nest egg in a U.S. Individual Retirement Account, Roth IRA, or Simplified Employee Pension IRA. This is a common scenario for many U.S. citizens and green card holders while working in the United States. In a scenario that is becoming increasingly more common, imagine that after years … Continue reading U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card
While a campaign promise by President Donald Trump to eliminate income taxes on Social Security benefit income was not fulfilled, seniors were granted certain relief. The landmark tax legislation, the One Big Beautiful Bill Act (H.R. 1), signed into law on July 4, 2025 introduced a temporary special deduction for taxpayers aged 65 or older. The Social Security Administration … Continue reading A Tale Of Two Retirees: New Senior Tax Deduction And Foreigners’ Social Security
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
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
A very informative podcast - I would say it's a crash course on the US #expatriation regime including the recently issued final IRS regs on the Sec. 2801 transfer tax, lots of tax tips including gifting issues to get below USD 2 million threshold, what NOT TO DO if CBP wants you to sign I-407 … Continue reading PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More
Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025. It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”
Foreign investors with assets in the United States often encounter complex estate tax rules that can significantly impact taxation of their U.S. assets at death. If the individual is a non-resident, non-citizen of the U.S. (NRNC), the U.S. estate tax applies only to assets situated or deemed to be situated within the U.S. (for example, … Continue reading U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens
Virginia - US TAX TALK 