This is the sixth in a series of articles on the US taxation of shipping income, and continues the explanation of exemptions from the tax available pursuant to Section 883. Future articles will cover the “look through” rule and what must be done to comply with the filing requirements associated with these exemptions. The tax…
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…
DetailsThis is the fourth in a series of articles on the US taxation of shipping income, and explains treaty exemptions from the tax, what they are, how companies qualify and what must be done to comply with the filing requirements associated with the treaty exemption. With very few exceptions (Greece is one of the exceptions),…
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…
DetailsThis is the third in a series of articles on the US taxation of shipping income, and explains treaty exemptions from the tax, what they are, how companies qualify and what must be done to comply with the filing requirements associated with the treaty exemption. As the first two articles in this series explained, the…
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,…
Details