November 9, 2015
tax planning for foreign corporations

Potential Tax Liabilities of a Foreign Trust or Estate

Are foreign trusts and estates subject to U.S. Estate and Gift taxes? The short answer: sometimes. The U.S. taxation on the transfers of property by a […]
August 15, 2015

Non-residents transfer property with no estate and gift tax

What is FIRPTA? The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) allows the IRS to tax foreign persons on the disposition of real […]
July 3, 2015

What to Know Before Considering a Decision to Expatriate

SECTION 877 AND EXPATRIATION IRC Section 877 virtually eliminates most of the tax benefit sought by expatriation (a decision to expatriate by moving out of the […]
March 26, 2014

I’m not a citizen but I have real property in the U.S.

This is a good question. Every foreign jurisdiction has a “choice-of-law” regulation that decides whether to apply its law or another jurisdiction’s law. A conflict between […]
March 26, 2014

Provisions to know in decedent’s testamentary instrument

With the assistance of an attorney it is important to determine the decedent’s intent. For this, ask whether distributions are to be made outright to the […]
March 26, 2014

Receiving gift or bequest from foreign individual

Traditionally, under United States taxing principles a transferor (party making a gift) making a gift or bequest is the one subject to transfer tax (gift or […]