This 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…
DetailsA letter (yes, an old-fashioned, sent-by-post, paper letter) arrived in my office today from an overseas lawyer seeking advice for his client. The client was born in the United States. When he was a month old, he returned with his parents to their home country, where he has now lived for more than 40 years.…
DetailsApropos being an accidental American, last week the Internal Revenue Service published a “Fact Sheet” which attempts to calm the waters upset by the widespread non-filing of US tax returns and foreign bank account reports by U.S. citizens. Quite frankly, there is very little in the Fact Sheet that is either surprising or new. Nonetheless,…
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…
DetailsThis blog addresses how U.S. birthright citizenship and U.S. citizenship taxation affect the millions of people around the world who have American citizenship by birth or by lineage. Specifically, I focus on people who were born in the U.S., have moved abroad, are citizens by heritage, or became naturalized citizens of other countries, and live…
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,…
DetailsApril 10th, 2009 BY FAX (TOTAL OF FIVE PAGES) AND REGULAR MAIL Fax No. 202-622-5756 The Honorable Douglas H. Shulman Commissioner of Internal Revenue 1111 Constitution Ave., NW, 3000 IR Washington, DC 20224 Re: Use of Offshore Bank Accounts to Evade Tax Honorable Sir: This letter addresses an aspect of the referenced subject that has…
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