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

Foreign trusts generally incur taxable income similar to nonresident noncitizen (NRNC) individuals, with certain limitations on credits and deductions that are source income.1

Published in Publications

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

A foreign trust is generally treated as a nonresident noncitizen (NRNC) holding for U.S. income tax purposes. Therefore, foreign trusts are subject to U.S. income tax only on U.S. source income.[1]

Published in Publications
Thursday, 08 June 2023 16:41

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.

Published in Publications

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

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:  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
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Forster Boughman & Lefkowitz

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