Corporate Transparency Act: BEWARE! The Scammers have Already Arrived!

As most of my readers know the Corporate Transparency Act (CTA) requires US entities (including for example, US LLCs, corporations, partnerships), and many foreign entities including those that register to do business in a state, to disclose to FinCEN of the Treasury Department, the identity of their beneficial owners. Information to be provided: name, date … Continue reading Corporate Transparency Act: BEWARE! The Scammers have Already Arrived! →

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 →

The Real World: When Foreigners Die Owning US Assets – Estate Tax, Federal Transfer Certificate and Related Troubles

My recent blog posts (e.g. here, and here) emphasized how important it is for Americans who are investing in foreign (non-US) assets to understand the US tax consequences of making that investment. Far too often I have seen individuals invest substantial amounts of money without knowing the tax impact of that infusion of hard-earned cash. … Continue reading The Real World: When Foreigners Die Owning US Assets – Estate Tax, Federal Transfer Certificate and Related Troubles →

Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All

If you or your clients are really (really) wealthy (more than $100 million in annual income or more than $1 billion in assets) and thinking about expatriation (relinquishing US citizenship or a green card as a long-term resident), the time is now. Even if not super wealthy, the newly proposed Billionaires Income Tax should serve … Continue reading Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All →

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 →

Tips for the Foreign Nonresident to Avoid Gift Tax when Gifting to Persons in the USA

Last week's blog post covered the US gift tax basics for foreign nonresidents wishing to make gifts to persons in the US. As discussed in that post, foreign nonresidents are generally subject to US gift tax only on tangible assets located, or deemed to be located, within the US at the time of the gift transfer. … Continue reading Tips for the Foreign Nonresident to Avoid Gift Tax when Gifting to Persons in the USA →

Foreign Persons Making Gifts to the US – Cash / Wire Transfers / Checks?

Understanding the US gift tax is important for both US and non-US persons. It comes as a big surprise to many people that US gift tax issues can arise in many unanticipated ways, such as sending money to an adult child attending college; making loans interest-free to family members or giving them loans with below-market interest rates. Even non-US persons can … Continue reading Foreign Persons Making Gifts to the US – Cash / Wire Transfers / Checks? →

The Perfect Storm – US Tax, Community Property & the Mobile International Couple

Last week I blogged about how the US tax system can create serious tax problems for the international couple when one is a US person and the other is not. In order to keep things simple, it is often advised that the couple hold assets separately to avoid nasty US tax complications. However, in some … Continue reading The Perfect Storm – US Tax, Community Property & the Mobile International Couple →

The US Tax Trap: International Marriage, Community Property and the Mobile Couple

Readers of my blog know from previous posts (for example here and here) that unless the international couple enjoys dealing with complicated US tax matters and filings, holding title to assets jointly with a non-US citizen spouse is risky business! The well-advised keep their assets completely separate to avoid nasty US tax complications. However, this alone … Continue reading The US Tax Trap: International Marriage, Community Property and the Mobile Couple →