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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

Friday, 01 July 2022 19:44

Expatriation from the United States: The Inheritance Tax Under I.R.C. §2801

Article Written for: Florida Bar Journal

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.

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

Friday, 17 December 2021 02:00

Expatriation from the United States, Part 2: The Inheritance Tax

Article Written for: Florida CPA Today, a publication by the Florida Institute of CPAs

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.

Published in Publications

Friday, 17 December 2021 01:00

Expatriation from the United States, Part 1: The Exit Tax

Article Written for: Florida CPA Today, a publication by the Florida Institute of CPAs

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.

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 presents at the FICPA South Florida Accounting Conference. He discusses the Inflation Reduction Act and its effect on domestic and international protective structuring.

16 December 2022

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Our News

Tax Reporting of Foreign Assets

Testamentary Transfers to Non-Citizen Spouses

The Status of LLCs in Asset Protection Planning

Expatriation from the United States: The Inheritance Tax Under I.R.C. §2801

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

Expatriation from the United States, Part 2: The Inheritance Tax

Expatriation from the United States, Part 1: The Exit Tax

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