We can help you cleanly exit from the US system -- we know the tax rules and have been through the process many times.Learn More
Buying the property correctly is the secret to tax success. We know how to set things up correctly from the start.Learn More
Trusts can act as a firewall against the US tax system, but are hard to do right. We create, terminate, and fix trusts.Learn More
For companies that operate across the US border, we can help with the complexity of US tax planning.Learn More
The United States has a wealth tax that is imposed at the time of death, called the “estate tax”. In round numbers, the first $5,500,000 of a person’s wealth (measured at the time of death) is tax-free, but everything above that is taxable. The top tax bracket is 40%.
You might have accumulated significant wealth before becoming a U.S. resident. You might wonder why the U.S. government should be entitled to take 40% of that away from your spouse, children, and grandchildren when you die.
It is not polite to say this out loud, but the estate tax is largely optional.... continue reading
Green card holders, if they give up their visa status as a permanent resident of the United States, can be hammered by the exit tax. But not all green card holders are at risk—only if you are a long-term resident.
Avoid becoming a long-term resident and the exit tax rules simply do not apply to you.
Let us look at how a green card holder can use an income tax treaty to avoid being a long-term resident.
Receiving a green card (and setting foot in the United States) makes you a resident of the United States for income tax purposes.... continue reading
Today’s post is about a few gaps between taxation under the subpart F rules for controlled foreign corporations and passive foreign investment company (PFIC) rules. If your business happens to fall into one of these gaps (or can be reconfigured to fall into one of these gaps), it can be useful for deferring US taxes on income.
Congress enacted the subpart F rules, applicable to controlled foreign corporations (CFCs), to prevent US persons from conducting certain kinds of operations through a corporation organized in a tax haven to avoid or defer US taxes.... continue reading
This article is for entrepreneurs who, for valid reasons, need to have a U.S. corporation to operate their businesses. Maybe the customers are in the United States. Maybe there is an office full of employees in the United States. Maybe banking and financial transactions are simpler when there is a U.S. corporation.1
The entrepreneur, however, decides to live abroad. Let’s use the phrase “digital nomad” (the current favorite appellation). This person is going to travel from place to place, working for the U.S. business, but staying below the radar in the various foreign countries.... continue reading
A joke should always be told punchline first. Right?
Here’s the conclusion of this little essay:
If you plan to file Form I-407 to abandon your green card, do it in person. If that is impossible, do not just mail in the form. Send it by certified mail, return receipt requested.
The U.S. tax effect of holding a green card visa is that you are considered a “resident alien” until the visa status is terminated. This means you must file a resident’s income tax return every year (Form 1040). You are taxable on your worldwide income, and must satisfy all of the paperwork requirements imposed by the U.S.... continue reading