I got an inquiry today from my FIRPTA.com website that I figured would be worth answering here, because it is a topic of general application. The question is whether using a foreign corporation works to protect against U.S. estate tax. Foreign corporations to hold U.S. real estate Nonresident investors frequently hold U.S. real estate using [...]

Today I gave an all-day course on U.S. taxation of nonresident investors in U.S. real estate. (Link is to the next time I’m giving this course — in San Jose on January 6, 2009). The course was sponsored by the Cal CPA Education Foundation. It was at the Sheraton in Anaheim, hard by Disneyland. No, [...]

The TaxProf blog has a recent post about expatriation. The TaxProf refers to a recent academic paper on the topic, which you can download here. It’s always interesting to see the academic perspective on something that I do, y’know, for money. Expatriation is mostly estate tax driven Giving up U.S. citizenship–when it is tax driven–is [...]

A reader of my November, 2008 article in California CPA Magazine (hi, David) called me and asked a question about the article. He wanted to clarify a generation-skipping transfer tax question. I didn’t have the space in the article to cover all of the nooks and crannies on the subject of estate taxation for cross-border [...]

I wrote an article for the California Society of CPAs and it was published in the November, 2008 edition of the California CPA. The article is about estate tax planning for multi-national families, or as I like to say, “tax planning when a border runs through your balance sheet.” You can find Planning for Cross-Border [...]