Tag: US Estate Tax

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 →

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 →

Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause”

We have had a taxpayer win in the foreign information reporting arena! I provide a summary of the case of Mr. Krzysztof Wrzesinski below.  For readers who wish more, the taxpayer’s complaint is here. Background of the Wrzesinski Case Mr. Wrzesinski (“Taxpayer” or “T”) was a native of Poland who immigrated to the United States … Continue reading Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause” →

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 →

Death of the American Abroad – Is the Estate a US or Foreign Estate? What to do with Undeclared Foreign Assets?

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? →

Breathing American Air – Hazardous to your Wealth? (Part II)

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) →

Breathing American Air – Hazardous to your Wealth? (Part I)

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) →

US Tax Inflation Adjustments for 2023 – Impact on the International Family

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 →

Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal 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? →