Article Written for: the MassCPA's Massachusetts Society of CPAs All U.S. situs assets held by a non-resident non-citizen (NRNC), both tangible and intangible, unless falling within a limited exemption, are subject to the U.S. estate tax. Those same assets held in a foreign corporation are excluded from estate tax.
In addition to the Exit Tax, the Heart Act added a new federal transfer tax, which imposes an "Inheritance" tax on certain gifts or bequests (testamentary dispositions) made by a "covered expatriate" to U.S. recipients. This is the second article in our two-part series on the expatriation tax.
Abandonment of United States citizenship or long-term residency (by non-citizens) may trigger the United States “expatriation tax”. The expatriation tax consists of the “Exit Tax” and the “Inheritance Tax.” In this first of our two-part series, we explain the Exit Tax.
Asset protection is a body of law that has developed as an amalgamation of business structures, trusts, titling and creditor exemptions. Asset protection planning insulates assets otherwise exposed to future unknown creditors. Prudent structuring uses widely accepted legal strategies to make clients unattractive to claimants.
Abandonment of U.S. citizenship or long-term residency (by non-citizens) may trigger U.S. income tax. The “expatriation tax” consists of two components: the “exit tax” and the “inheritance tax.” Both may be triggered upon abandonment of citizenship or (for non-citizens) abandonment of a green card by a long-term resident. In this first of our two-part series, we explain some of the principal terms of the exit tax.