Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory

In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory →

U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card

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 →

Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC

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 →

5 U.S. Estate Tax Surprises For Nonresident Alien Investors

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 →

Executor Beware: Personal Liability for Unpaid Estate Tax and More

Serving as the executor of an estate is not just an administrative duty. It involves significant legal responsibilities, particularly when it comes to ensuring that all tax obligations of the deceased are properly addressed. Executors must locate the estate’s assets, assess debts and liabilities, and make distributions to beneficiaries. Critically, they must do all this … Continue reading Executor Beware: Personal Liability for Unpaid Estate Tax and More →

U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens

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 →

No U.S. Tax Honeymoon When Americans Marry Non-U.S. Citizens

My article copied below, first appeared on Forbes May 11, 2024 – link here. It provides some important tax tips for those in a US/non-US citizen mixed marriage! Follow me on Forbes for easy to understand US international tax coverage. I’d loved to be your “go-to” person when it comes to US tax issues impacting Americans … Continue reading No U.S. Tax Honeymoon When Americans Marry Non-U.S. Citizens →

Death Of The American Abroad: Untangling U.S. Tax Across Borders

Many of my readers know I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 22, 2024 here. In our global society, more and more Americans are living and working overseas. This inevitably … Continue reading Death Of The American Abroad: Untangling U.S. Tax Across Borders →

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 →