Foreign investors can win big with United States investments. While holding U.S. assets can be lucrative, the U.S. estate tax regime is complex and often misunderstood by nonresident alien investors. NRAs, those who are neither U.S. citizens nor residents for estate tax purposes, are often very surprised when they learn of the challenges imposed by the … Continue reading 5 U.S. Estate Tax Surprises For Nonresident Alien Investors
Tag: US tax
What Tax Advisers Should Tell U.S. Clients Moving to Latin America
I am proud to share this article published by Bloomberg Tax (April 30, 2025), co-authored with Sofia Larrea, a dynamic young attorney based in Ecuador. As Latin America strives to be more noticed on the world stage, here are some important pointers about its tax laws and community property regimes which impact US taxpayers who … Continue reading What Tax Advisers Should Tell U.S. Clients Moving to Latin America
Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely
The Additional Child Tax Credit can provide taxpayers up to $1,700 per qualifying child in 2025 as a refundable credit. The ACTC not only reduces the amount of tax owed but can also result in a refund from the IRS if the credit exceeds the tax liability. Non-refundable credits can only reduce a taxpayer’s tax … Continue reading Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely
Executor Beware: Personal Liability for Unpaid Estate Tax and More
Serving as the executor of an estate is not just an administrative duty. It involves significant legal responsibilities, particularly when it comes to ensuring that all tax obligations of the deceased are properly addressed. Executors must locate the estate’s assets, assess debts and liabilities, and make distributions to beneficiaries. Critically, they must do all this … Continue reading Executor Beware: Personal Liability for Unpaid Estate Tax and More
Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules
When it comes to estate planning, how you hold property with others can have significant tax implications after you have passed on. Internal Revenue Code Section 2040 governs how joint ownership of property with right of survivorship is treated for federal estate tax purposes. The rules can catch even the most astute investors off guard. … Continue reading Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules
Leaked Memo Includes Major Tax Reform And Impacts U.S. Persons Abroad
A recently leaked memorandum discussed by JD Supra, has revealed potential tax reform under discussion in the U.S. House of Representatives. These share some key elements with President Donald Trump’s tax reform proposals, reflecting a coordinated effort to implement significant change. The leaked information contains changes that could reshape the tax obligations of U.S. persons … Continue reading Leaked Memo Includes Major Tax Reform And Impacts U.S. Persons Abroad
Giving Up Citizenship Or Green Card: Harsh Tax On Social Security
A portion of an individual’s U.S. Social Security retirement, survivors, or disability benefits may be subject to U.S. income tax, regardless if the individual is a U.S. or non-U.S. person. Before delving into the details about tax on Social Security, it is helpful to understand the different nomenclature when it comes to certain benefits. Social … Continue reading Giving Up Citizenship Or Green Card: Harsh Tax On Social Security
40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”
Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025. It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”
U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens
Foreign investors with assets in the United States often encounter complex estate tax rules that can significantly impact taxation of their U.S. assets at death. If the individual is a non-resident, non-citizen of the U.S. (NRNC), the U.S. estate tax applies only to assets situated or deemed to be situated within the U.S. (for example, … Continue reading U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens
Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons
The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons









