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Article Written for:  Florida Bar Journal

A foreign trust is generally treated as a non-resident/non-citizen (NRNC) for U.S. tax purposes. Foreign trusts are therefore subject to U.S. income tax only on U.S. source income.[1]

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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.

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Article Written for:  Florida Bar Journal

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.

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