With more and more Americans living and working abroad, the reality is that US persons will also pass away while residing in a foreign country. Did you know that a US citizen residing abroad at death may have a “foreign estate” for US income tax purposes? What does that mean for the estate? What does … Continue reading Death of the American Abroad – Is the Estate a US or Foreign Estate? What to do with Undeclared Foreign Assets?
Part 1 of this blog post introduced readers to some of the issues surrounding US taxation of foreign persons and discussed the pitfalls of tax ignorance. This 2-part series identifies areas of potential US tax exposure for foreign nationals and examines the questions the foreign person and his advisors should be asking before taking a … Continue reading Breathing American Air – Hazardous to your Wealth? (Part II)
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
Part I of this blog post examined the US tax issues faced by the Duke of Sussex who moved with Duchess Meghan to Los Angeles in March 2020. Given the significant number of days of physical presence in America, Prince Harry has most likely already met the "substantial presence test" and is being taxed the … Continue reading Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?
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
Today's post, Part II, was written with my colleague John Richardson, J.D. Part I of this blog post discussed President Biden's Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death. To recap, the major thrust of the Green Book proposal is to treat gifts … Continue reading Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard
Today's post is in two parts and was written with my colleague John Richardson, J.D. On March 28, President Joe Biden released the FY2023 Budget, also known as the Green Book, available here. The Green Book is not proposed legislation, but it might be viewed as a kind of reading of the tea leaves showing … Continue reading “With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)
The House Ways and Means Committee recently released its proposal (HWM Proposal) to fund the US$3.5 trillion "Build Back Better Act" reconciliation spending package. Not unexpectedly, the proposal takes aim at high income earners. Here’s a few pointers that are important for many of my readers, especially those with US trusts or those looking at … Continue reading Coming Soon! Higher Income and Capital Gains Taxes & More – Beware Trusts, Expatriation Planning
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!