Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
Foreigner asks: “Can I breathe American air without being subject to US tax?” The answer to that question is a big, fat MAYBE. For starters, it depends how long you were in the US breathing that air. While the question might sound funny, there is absolute truth in the answer. It amazes me how many … Continue reading Breathing American Air – Hazardous to your Wealth? (Part I)
Certain provisions in the United States Internal Revenue Code (Code) are tied to inflation to prevent rising prices from resulting in higher taxes. Annual inflation adjustments have been part of the tax rules for well over 2 decades. These formulas set by Congress help prevent inflation from nudging taxpayers into higher tax brackets and increasing … Continue reading US Tax Inflation Adjustments for 2023 – Impact on the International Family
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
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
Given today’s global economy it comes as no surprise that US taxpayers and the Internal Revenue Service (IRS) must increasingly consider the interactions between US and foreign laws when determining the US tax consequences of a particular transaction. In today’s world, it is no longer possible for practitioners to ignore the possible implications of another … Continue reading HELP! What to do When Foreign Law Impacts the US Tax Analysis of My Case?
US “residents” are subject to tax on income derived from all sources. That means they are subject to tax on their worldwide income regardless of the source of that income. So, for example, dividends earned from a French company are taxable, as is gain on the sale of rental property located in Hong Kong; prize money won … Continue reading Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
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
Virginia - US TAX TALK 