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?
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
It’s been no secret that the Internal Revenue Service (IRS) has cracked down on crypto. With many more taxpayers investing in cryptocurrencies the agency has targeted crypto investors who are often not complying with the US tax rules (many unknowingly). IRS “John Doe” subpoena activity of crypto exchanges has been successful with the biggies such … Continue reading Checked “YES” to the Crypto Question on Form 1040? Have NFTs? Get Ready….
Anyone out there thinking about estate tax planning, asset protection, making gifts? And, what about those considering expatriation? I am fielding many more inquiries about expatriation these days. Well, if you are considering any of these things, my sage advice would be to hurry up. Major transfer tax law changes look to be on the … Continue reading Senator Sanders – Gift and Estate Tax Reform Proposals Pack a Punch
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?
Janet Yellen, the former Federal Reserve chairperson is now the new US Secretary of the Treasury. She has staunchly defended President Biden's plan to reduce the estate-tax exemption amount from the current US$11.5 million to US$3.5 million, as well as to increase the top estate tax rate from 40% to 45%. In responding to criticism … Continue reading Estate Taxes Going Up – Is There Still a Golden Gifting Opportunity?
Many individuals have questions about the US tax consequences of foreign (non-US) assets inherited from a non-US individual who has passed away. They want to know whether US tax reporting is required, or if they must pay US tax on the inheritance. Some ask about the US tax upon a later sale of the inherited … Continue reading US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust
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!