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Trusts can act as a firewall against the US tax system, but are hard to do right. We create, terminate, and fix trusts.

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September 14, 2017

Income Tax Return Extension Until December 15, 2017

If you are an American living abroad and sweating the October 15 tax filing deadline for your 2016 income tax returns, there is a possible piece of relief. You may be able to qualify for a further extension of time for filing your tax return — to December 15, 2017.


For American taxpayers living abroad, if you want to get a filing deadline of December 15, 2017 for your 2016 Form 1040, do this:

  • On or before June 15, 2017, file Form 4868.
  • On or before June 15, 2017, pay whatever tax you have to pay for 2016, along with that Form 4868 you are filing.
... continue reading
September 12, 2017

How to Handle Inheritances from an Expatriate

Everyone focuses on the income tax side of expatriation. Understandable. The year of giving up U.S. citizenship or permanent residence is a busy year and income tax is painful.

But estate tax problems can lurk, even after expatriation. Expatriates receiving inheritances from U.S. persons is one side of the equation.

Let’s look at the other side of the equation: money flowing back to the U.S. when an expatriate dies.

An expatriate (covered or otherwise) leaves an inheritance to a U.S. person. Here are the questions to ask:

  • What assets belonging to the expatriate (covered or noncovered) are hit with the U.S.
... continue reading
September 7, 2017

Unit Trust in Stapled Security Arrangements

This is a question sent to us through email:

I invested in Australian stapled securities. Do I have a PFIC problem?

In this post, I will introduce the concept of stapled securities and go through the questions we ask to determine whether the US person holds a PFIC. Because we have limited space, I am going to assume that the particular stapled security we are discussing is used to hold real estate investments.

What are stapled securities?

It is a type of securities arrangement in Australia.

You have a unit trust that holds property. The unit trust hires a limited company to manage the property.... continue reading

September 1, 2017

When a Foreign Trust Files FinCEN Form 114

The Problem

This week, I want to highlight a risk: when an unanticipated FinCEN Form 114 filing requirement might apply to a trust.

There is a weird situation where a foreign trust (as defined for income tax purposes) may be required to file FinCEN Form 114. (FinCEN Form 114 is how you tell the U.S. government about your foreign financial accounts).

It’s weird, but intentional.

Short Attention Span Summary

Does the trust look like a normal domestic trust but get taxed as a foreign trust? Watch out. You have a potential FinCEN Form 114 filing requirement.

Look Domestic, Taxed Foreign

There are good reasons to create trusts that look like domestic trusts but are taxed as foreign trusts.... continue reading

August 29, 2017

Expatriates Receiving Inheritances from U.S. Persons

Let’s say you have expatriated (gave up U.S. citizenship or your green card) and you expect to receive an inheritance from a U.S. person–perhaps your parents.

How is that inheritance taxed?

Correspondent KP emailed me to ask exactly this question. (Hint: you can email ask a question, too; just hit reply and suggest a topic or ask a question for me to answer in the newsletter).

Perhaps you have already answered this in the expatriation blog and I just couldn’t find it (in which case, please send me a link), or it might be worth considering as a future topic:

If a person has renounced US citizenship, filed the 8854, and IS -for all intents and purposes- considered to be a non-resident non-citizen, what US tax/reporting obligations come into play if said person inherits a US estate from a US citizen & resident relative?

... continue reading
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