US Citizenship: Do You Really Want It? Brave New World – Assisted Reproductive Technology / Surrogacy / Same-sex Marriage

My earlier blog post discussed some of the complications that arise when certain individuals wish to renounce their US citizenship. The would-be renunciant must give up US citizenship “voluntarily” and with the requisite “intention” in order to meet the legal requirements for an effective renunciation. This can be a difficult hurdle to surmount in the … Continue reading US Citizenship: Do You Really Want It? Brave New World – Assisted Reproductive Technology / Surrogacy / Same-sex Marriage

Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA

Over my many years of international tax practice, I regularly come across the loving foreign parent (or relative) with a child (or other relation) residing in the United States. The individual may be studying there or living there and pursuing the American dream - starting a business or perhaps buying a home. He or she … Continue reading Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA

US Residency “First Year Election” and FBAR – The Devil is in the Details

Recently, I presented a webinar for tax pro’s earning CPE credits; the topic involved our favorite character, Mr. FBAR. The FBAR, Form 114, is more formally known as the Report of Foreign Bank and Financial Accounts.  The webinar will be available soon as a CPE credit "self-study" program.  Send me an email if you wish … Continue reading US Residency “First Year Election” and FBAR – The Devil is in the Details

FBAR Traps: International Couples, Powers of Attorney

Meet the Zuhovitzky’s, the quintessential international couple: Jonathan (a naturalized US citizen and Israeli citizen living in Germany) and Esther (an Austrian and Israeli citizen who was never a US citizen or resident).  I blogged about them and the IRS’ aggressive stance on asserting so-called FBAR penalties against Jonathan for having a power of attorney … Continue reading FBAR Traps: International Couples, Powers of Attorney

Covered Expatriates, Exit Tax and the Principal Residence

My earlier blog post discussed the rules that apply to a US taxpayer who sells his personal residence, whether located abroad or in the US. If the home qualifies as the “principal residence” and other requirements are satisfied the taxpayer may exclude up to US$250,000 ($500,000 for joint returns) of taxable gain from income.  As … Continue reading Covered Expatriates, Exit Tax and the Principal Residence

Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

Last week's blog post looked at one way that a non-US citizen can become subject to US income tax on his or her worldwide income - simply by getting a US green card.  Today's post looks at the other way one can fall into the US tax trap. “Substantial Presence” in the US An individual … Continue reading Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

US Tax Planning Before Immigrating to the United States

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

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

IRS Tells You if You are Married and to Who! Yes, IRS has Rules For That!

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!