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
Let us imagine that you are planning to expatriate in 2018, and that you will be a covered expatriate. You have a number of rental properties in the United States. Those rental properties have accumulated a substantial amount of passive activity losses (PALs) during the time that you have owned them. Because you are a covered expatriate, you will need to pretend you sold all those properties at fair market value on the day before your expatriation and report the gains or losses on your tax return as if you really sold the properties.... continue reading
I received an email from a practitioner this morning and figured it’s worth a blog post.
Reader C in Sydney asked me:
Election to be a U.S. taxpayer
Would a MFJ couple (US citizen and NRA Spouse) using Sec 6013(g) Election qualify for Unlimited Spousal transfer from decedent US Citizen? Inquiring minds would like to know 🙂
Nonresidents who are married to U.S. persons (citizens or residents for income tax purposes) can choose to be fully subject to U.S. income tax laws. Ordinarily, a sane person would attempt to avoid this status, if possible.
But sometimes we do the math and it actually saves tax overall to do so. ... continue reading
Let’s look at the taxation of income earned by spouses living in community property jurisdictions. When a U.S. person is married to a nonresident alien, the tax rules are different.The normal rules: two U.S. taxpayers
The normal rules are described in IRS Publication 555.1 Where spouses are subject to community property rules and they file separately, community income is split equally between the two spouses. The community property jurisdiction might be California. Or it might be any one of a number of countries outside the United States.Different rules for a nonresident alien spouse
When one of the spouses is a nonresident alien, the rules are different.... continue reading
We are just a few short days away from a very important date. If you expatriated during 2017, chances are you need to file your tax return and Form 8854 by June 15, 2018. You also need to make full payment of any tax due by that date.
If you need more time to get the tax return ready, you can file for an extension to December 15. However, the payment due date remains June 15, 2018.
Today’s topic will be limited to a description of the filing and payment deadlines for expatriates and how to get an extension to file your tax return.... continue reading
Today’s post is for individuals living abroad who file their tax returns on June 15 and who have deemed repatriation income from their foreign corporations under section 965.
A quick introduction to section 965: In December of 2017, Congress passed laws that changed the US taxation of foreign income significantly. One of these laws is section 965.
There are many nuances to section 965, but here is the short version that covers what we need today: If you are a US citizen, green card holder, or other resident, or you are a US entity; and you own at least 10% of a foreign corporation, you might have a lot of income from the deemed repatriation of your share of the foreign corporations’ accumulated profits since 1986.... continue reading