The United States has a gift tax: if you give something to someone, you have to pay the U.S. government for the privilege. Yes there are a ton of exceptions and weird rules. This is tax law after all. But you’d be surprised who gets tangled up in the gift tax law. Consider this one. [...]

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 [...]

In response to an email I just got from Denis Carrade, here’s another resource. Denis, you remember we talked in the class yesterday about the interesting situation of having a corporation, and the corporation’s assets are being used by the shareholder for personal purposes. I can hear the brain klaxons firing up now, just thinking [...]

For all of the people who were in my “Foreign Investment in U.S. Real Estate” class yesterday in San Francisco (I taught a 1-day course sponsored by the California Society of CPAs Education Foundation), here is one of the things I promised to deliver. Tax Court Opinion The Estate of Fung attached (warning: PDF) are [...]

I’ve been published again. This time it’s an article titled “A Quick Overview of U.S. Taxation of Nonresident Aliens,” published in 13 California International Practitioner 2 (2004). This is the quarterly publication of the International Law Section of the State Bar of California. It’s Volume 13, Number 1. Sorry I don’t have the ability to [...]