Foreign Trusts: Income Tax and the U.S. Grantor
Article Written for: The Inheritance Tax under IRC §2801
Article Written for: TaxStringer, the NYSSCPA's (New York Society of Certified Public Accountants)
The Heart Act added a new federal Inheritance Tax on certain lifetime and testamentary dispositions to U.S. recipients, made by a “covered expatriate.” This is the second article in our two-part series on the expatriation tax.
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.
Estate and Gift Tax Rules for Noncitizens
Take a Close Look at LLCs when Asset Protection Planning
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.
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
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