Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time. This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR). Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others! →

Using a “Foreign Grantor Trust” – I Heard of it, but Hmmmm … I Want to Know More

Most tax practitioners and wealth planning professionals have heard of the “foreign grantor trust” (FGT) but many are unsure of what it is, how it works, or what it can accomplish in US tax planning. My post today provides an overview. The use of a so-called “foreign grantor trust” is a traditional planning technique that … Continue reading Using a “Foreign Grantor Trust” – I Heard of it, but Hmmmm … I Want to Know More →

Rich Americans…. Time to Wake Up!

Rich Americans (or foreigners with US assets), it's time to wake up and smell the coffee! Why? I am seeing more and more individuals with influence pushing for a change in the US tax laws so that wealth inequality becomes a thing of the past. Whether you agree with this position is not the point … Continue reading Rich Americans…. Time to Wake Up! →

Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health

Recently, I am seeing more and more married couples of dual nationality (with one US individual partner) struggling with the US tax issues wrought by such a "mixed marriage". Some are same sex couples married under the laws of a foreign (non-US) jurisdiction. Believe it or not, marriages taking place in a foreign country (whether … Continue reading Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health →

Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now

The US gift tax is a tax imposed on the transfer of property by way of gift. The giver of the gift (the donor) is the party who must pay the tax. Generally, any transfer to an individual without receiving something of equal value in return (measured in money or money's worth) is treated as … Continue reading Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now →

Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

On April 9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments →

Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners

With Christmas having recently been on our doorstep, now is the time to review what tax consequences are in store for gift givers and their lucky recipients. US tax filings might be required of a US individual who receives a gift (whether in cash or property of some kind - you know, a 5 carat … Continue reading Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners →

Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008. The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely →

The #FBAR Marriage – A Troublesome Union

I was just recently interviewed on Canadian TV in 3 different sessions covering the US tax complications when a US person and non-US person are married (US income tax, gift tax, estate tax). I am being interviewed by John Richardson, a Canadian and US attorney. John calls this phenomenon the #FBARMarriage. Some marriages don't last -- … Continue reading The #FBAR Marriage – A Troublesome Union →

Gifts & Bequests from Former Americans – Beware that Trojan Horse

Former US citizens or long term permanent residents who are giving up (or previously gave up) their US status, have far more than just the "Exit Tax" to worry about. They must also consider the impact the expatriation will have on their US family members and other intended US beneficiaries. I'm still waiting for more … Continue reading Gifts & Bequests from Former Americans – Beware that Trojan Horse →