On December 3, 2012, the US and Switzerland initialed a bilateral agreement to implement Foreign Account Tax Compliance Act (FATCA) (the agreement must still be approved by the Swiss Parliament). Previously, on November 20, 2012, Spain announced that it had agreed to a bilateral agreement implementing FATCA and on November 19, 2012, the IRS announced…
DetailsBy Ji Zhang, Esq., 2012/07/26 When foreign companies work through US subsidiaries to conduct business in the US, it can bring up complicated issues of who should be held responsible for the tax, and at what rate. For example, during years 2004-2007, DeCoro Limited (Parent), a Hong Kong limited liability company, manufactured furniture in China. DeCoro USA…
DetailsDebt obligations issued by the US government are defined as US property for estate tax purposes. Yet, what if you diversified your portfolio and have an US bank account? Would these things also count as it property within the US? It depends. Say you deposit $75,000 into ABC Bank, which is located in the US. …
DetailsThis week, we will start with a simple issue. Say you invested in Treasury Bonds. Did you know that it property within the US for estate tax purposes, even if you are a nonresident noncitizen of the US? Debt obligations of a US person are categorized as property within the US for estate tax purposes.[1] …
DetailsIf a foreign estate owns works of art located within the US, it poses an interesting question. The Internal Revenue Code states the value of the US gross estate for a non-US citizen includes property, which at the time of his death is situated in the US.[1] Let’s say Sam, a non-US citizen, owns works…
DetailsSo what property has to be included on a US estate tax return? The Internal Revenue Code states the value of the estate of a foreign individual is the part of his estate situated in the US at the time of his death.[1] In 2010, foreign governments and individuals invested $1,245.7 billion, excluding derivatives, in US…
DetailsHave you discovered the estate of a non-US citizen that contains US property? What appears to be US property may not always be considered such by the Internal Revenue Service. The Internal Revenue Code provides specific categories of property situated within the US and property situated outside the US. If you discover the foreign citizen’s estate…
DetailsThose U.S. citizens, birthright or otherwise, who wish to set their U.S. citizenship aside for whatever reason have two options: renunciation or relinquishment. Renunciation is exactly what the word implies. It is a formal sworn declaration renouncing U.S.citizenship. The procedures for renunciation are well known and straightforward. Consular Officers are generally familiar with the renunciation…
DetailsThe moment a nonresident, non-US citizen passes away with US property in his possession, the US estate tax clock starts to tick away the minutes to when the return is due. The Internal Revenue Service requires a foreign estate that owns US property to file an estate tax return within 9 months after the date of…
DetailsAs the saying goes, there’s nothing more certain than death and taxes. That phase comes to life, pardon the expression, when a person dies owning property. If the property is located in the United States or is consider “U.S. property” at the time of the owner’s death, even if the deceased was a non-resident foreigner,…
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