Exit Tax

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Wednesday, 01 February 2023 16:12

Expatriation from the United States Part 1: The Exit Tax

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

The U.S. imposes an Expatriation Tax on U.S. citizens who abandon citizenship and on or long-term U.S. residents (non-citizens) who surrender their green card. The expatriation tax consists of the Exit Tax and the Inheritance Tax. This article explains the Exit Tax.

Published in Publications

Monday, 30 January 2023 00:00

Estate and Gift Tax Rules for Noncitizens

Article Written for: the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants

Although CPA practices commonly handle federal estate and gift tax matters, very few CPAs counsel nonresident noncitizens exposed to these taxes. This blog provides an overview of the international side of U.S. estate and gift taxes.

Published in Publications

Monday, 22 August 2022 21:12

Take a Close Look at LLCs when Asset Protection Planning

Article Written for: the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants

Limited liability companies (LLCs) insulate owners from “inside” business liabilities, similar to corporations, but, unlike corporate stock, member equity held in a protective LLC generally may not be reached. Also, an “outside” creditor of an LLC member cannot acquire voting equity in a protective LLC, nor reach LLC assets. Claims on LLC interests are generally limited to a charging lien. These asset protection measures are just a few of the reasons LLCs have largely become the business entity of choice.

Published in Publications

Thursday, 01 December 2022 13:13

Tax Reporting of Foreign Assets

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

U.S. citizens and residents are subject to a number of IRS reporting requirements regarding assets held outside the U.S. Foreign situs assets and interests in offshore trusts significantly complicate tax reporting. Several such filing requirements are outlined below.

Published in Publications

Saturday, 01 October 2022 21:20

Testamentary Transfers to Non-Citizen Spouses

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

Published in Publications

Monday, 01 August 2022 14:42

The Status of LLCs in Asset Protection Planning

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

Published in Publications

Monday, 27 June 2022 00:00

Careful with Asset Protection Transfers: Courts May View Them as Fraudulent

Article Written for: the CPA Now, PICPA Pennsylvania Institute of Certified Public Accountants
An effective asset protection plan must be implemented before any foreseeable clams, as existing debts and anticipated liabilities are not avoidable. Reactionary transfers (made to avoid a present or future creditor) are reversible.

Published in Publications

Thursday, 09 June 2022 00:00

Using the Foreign Corporation to Avoid Estate Tax

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.

Published in Publications

Sunday, 01 May 2022 00:00

Estate Tax Planning for NRNCs Using the Foreign Corporation

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

Shifting Assets from U.S. SITUS

Published in Publications

Tuesday, 01 March 2022 00:00

The Non-Citizen and the U.S. Estate and Gift Tax – An Introduction

Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)

This month, we introduce our series on international tax law. We start with an introduction to the international aspects of the U.S. estate tax and the gift tax.

Published in Publications

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Our mission is to serve as a resource for complex domestic and international business transactions, tax, health law, asset protection, and related litigation.

Our firm is an approachable and economic alternative to large national and international law firms. Se habla español.

Gary and Brian present for the Estate Planning Council of Naples, discussing offshore structures, tax strategies, and best practices in asset protection, in their seminar: "Foreign Asset Protection and Tax Planning."

29 November 2023

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Our News

Expatriation from the United States Part 1: The Exit Tax

Estate and Gift Tax Rules for Noncitizens

Take a Close Look at LLCs when Asset Protection Planning

Tax Reporting of Foreign Assets

Testamentary Transfers to Non-Citizen Spouses

The Status of LLCs in Asset Protection Planning

Careful with Asset Protection Transfers: Courts May View Them as Fraudulent

Using the Foreign Corporation to Avoid Estate Tax

Estate Tax Planning for NRNCs Using the Foreign Corporation

The Non-Citizen and the U.S. Estate and Gift Tax – An Introduction

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