Many people do not think about the possible US tax planning techniques available to them before they become taxed as US “residents”. Once taxed as a US "resident" (e.g., a green card holder) the individual must clearly understand they are liable for US income tax on their worldwide income, in the same manner as a … Continue reading US Tax Planning Before Immigrating to the United States
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!
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
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!
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
Last week during testimony to the Senate Finance Committee (SFC), US Internal Revenue Service Commissioner (IRS) Charles Rettig stated that Congress needs to provide clear statutory authority in order for the IRS to collect information on cryptocurrency transfers valued over US$10,000. It is believed that such transfers are generally not being reported. Cryptocurrency market capitalization … Continue reading IRS Wants Crypto Information from Foreign Countries
Today’s post involving the case of Jonathan Zuhovitzky presents some important takeaways: The IRS can get very aggressive when it comes to assessing “willful” FBAR penalties. We see this trend is on the rise. A diligent representative, however, can get the IRS to settle an FBAR matter that is favorable to the taxpayer. It takes … Continue reading Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?
Why should I blog about a possible wealth tax in California? After all, my US tax blog focusses on international tax matters, US persons abroad, and foreign families with any US connections. Well, for starters, many of my clients are foreign nationals who (prior to COVID-19) enjoy visiting the US, or have specialized medical treatment … Continue reading Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days
Many individuals have questions about the US tax consequences of foreign (non-US) assets inherited from a non-US individual who has passed away. They want to know whether US tax reporting is required, or if they must pay US tax on the inheritance. Some ask about the US tax upon a later sale of the inherited … Continue reading US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust