Foreign Individuals: US Estate Tax Reform Passed You By (Part II)

Part I of this blog post examined some of the rules regarding the US estate tax and how it applies to non-US persons (noncitizen/nonresident). Unfortunately, the US estate tax often catches the nonresident alien family by surprise and when it does, it bites hard.  Remember, the "nonresident alien" will include an individual who has expatriated (e.g., … Continue reading Foreign Individuals: US Estate Tax Reform Passed You By (Part II)

Foreign Individuals: US Estate Tax Reform Passed You By (Part I)

Prior to the actual passage of the “Tax Cuts and Jobs Act” (TCJA) on December 22 2017, there were some high expectations that the disparity in the US estate tax exemption for US and non-US persons would be eliminated, or that the US estate tax itself would be repealed. Unfortunately, neither of these hoped-for events … Continue reading Foreign Individuals: US Estate Tax Reform Passed You By (Part I)

Foreign Nationals – Am I “Resident” for US Estate & Gift Tax Purposes?

Many non-US individuals come to me with questions concerning their liability for US taxes - income, gift, estate tax.  I find there are some general misunderstandings - hardly surprising given the complexity of the US tax system.  Let's review! Before we talk about foreign (non-US) individuals, let's be clear: US citizens are always treated as … Continue reading Foreign Nationals – Am I “Resident” for US Estate & Gift Tax Purposes?

All the Fun Rules — US Estate Tax for Nonresident Alien Individuals

Very few US Estate tax returns are actually filed by the estates of nonresident alien individuals. Statistics indicate that the amount of Estate Tax earned by the US Government on such returns is quite small.  The cost of structuring to avoid the tax is probably of far greater magnitude than what is collected by the US … Continue reading All the Fun Rules — US Estate Tax for Nonresident Alien Individuals