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 […]
Regulation § 1.6012-2(g)(1) requires foreign corporations that are viewed under the IRC to be engaged in ongoing U.S. trade or business activity to file Form 1120-F […]
Possibly. It is often very difficult to entirely remove oneself from the U.S. tax system, but with proper exit planning the associated tax bite can be […]
The Exit Tax includes both an income tax and an inheritance tax element. The income tax element consists of a deemed “mark‐to‐market” tax on the inherent […]
Yes, there are income tax and transfer tax (gift, estate, and generation‐skipping transfer) consequences to obtaining U.S. Citizenship (or Permanent U.S. Resident Status). Careful consideration should […]