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International Tax

Non-Resident Alien and Non-Citizen Services

Nonresident Options for Unreported Rental Income of U.S. Real Estate

Posted on 05/15/19 by Ann Harman

A nonresident renting U.S. real estate has two options as to how this activity will be taxed at the federal level.  Oftentimes, a nonresident does not become aware of these requirements until the year that the property is sold.  At that point, there is no good solution to becoming compliant.  While there are alternatives available,

U.S. Estate Tax and Residents of Germany

Posted on 09/13/18 by Renea M. Glendinning

Effective January 1, 2018, the Tax Cuts and Jobs Act granted U.S. citizens and domiciliaries an exemption of $11,180,000 with respect to U.S. estate tax for decedents dying in 2018. This means that individuals subject to the U.S. estate tax on the value of their worldwide assets do not pay U.S. estate tax unless the

Foreign Nationals and U.S. Estate Tax

Posted on 08/17/18 by Renea M. Glendinning, CPA

Many foreign nationals own U.S. real estate and hold title in their individual names.  They are often surprised to learn that if they still own the property at the time of their death, U.S. estate tax could be payable. The tax laws with respect to U.S. estate taxation of U.S. citizens and domiciliaries differ significantly

U.S. Estate Tax and Cross-Border Benefits for Canadians

Posted on 08/16/18 by Renea M. Glendinning

The American Taxpayer Relief Act of 2012 was passed in January 2013 and granted U.S. citizens and domiciliaries an exemption of $5,250,000 with respect to U.S. estate tax for decedents dying in 2013.  Persons subject to the U.S. estate tax on the value of their worldwide assets do not pay U.S. estate tax unless the

United States Estate Tax and Residents of the United Kingdom

Posted on 08/16/18 by Renea M. Glendinning

Many residents of the United Kingdom own property in Florida and in other parts of the United States. In the years past, the U.S. estate tax obligation on U.K. residents who died while owning property in the U.S. titled in their personal names could be quite significant. Recent changes in the U.S. estate tax laws

Sale of Partnership Interest by Foreign Persons

Posted on 08/08/18 by David Cumberland, CPA/ CGMA

New Rules for Foreign Persons Selling Partnership Interests The passing of comprehensive tax reform at the end of 2017 brought many changes. One change relates to the handling of the sale of partnership interests by foreign persons. Prior to the tax law change, withholding had not been required for the sale of a partnership interest

U.S. Gift Taxation of Nonresident Aliens

Posted on 06/08/18 by Renea M. Glendinning

U.S. gift tax can apply to nonresident aliens under certain circumstances. Gifts of tangible personal property and real property by nonresident aliens are subject to gift tax only if the property is located in the United States. Gifts of U.S. intangible property by nonresident aliens are not subject to gift tax. Nonresident aliens receive a

U.S. Income Tax Reporting on Rental Income for Nonresidents

Posted on 06/08/18 by Renea M. Glendinning

When a nonresident individual owns rental real estate in the U.S., there are two alternatives for reporting and paying U.S. income taxes. The individual may choose to not file an income tax return in the U.S. to report the rental income.  In this case, 30% of the gross rental income must be remitted to the

New Reporting Requirements for Disregarded Entities with a Foreign Owner

Posted on 11/03/17 by David A. Cumberland, CPA/CGMA

Any entity that is not recognized for U.S. tax purposes is a disregarded entity. The most typical and widely- used domestic disregarded entity is a single member Limited Liability Company (SMLLC). If a SMLLC has made the election to be treated as a corporation, the new regulations do not apply as it is no longer

Foreign Nationals and U.S. Income Tax and Disclosures: When Is Reporting Required?

Posted on 02/07/17 by Renea M. Glendinning, CPA

Each year, millions of foreign nationals visit the U.S.  Many of them come for a holiday and do not stay a sufficient amount of time in the U.S. to require them to file anything with the Internal Revenue Service (IRS), the U.S. government agency responsible for the tax collection and tax law enforcement.  However, foreign

Foreign Nationals and Like-Kind Exchanges

Posted on 01/18/17 by Renea M. Glendinning, CPA

Under the provisions of Code Section 1031, a taxpayer may sell U.S. real estate at a profit and defer paying tax on that profit by replacing it with the purchase of another property.  There are specific provisions which must be met in order for the transaction to qualify for tax-deferred treatment that are beyond the

Foreign Nationals and U.S. Gift Tax Consequences of Executing Certain Real Property Deeds

Posted on 01/18/17 by Renea M. Glendinning CPA

There are many ways in which foreign nationals can hold title to U.S. real estate.  Title may be held through various entities (i.e., corporations, partnerships, limited liability companies, trusts) or can be held in an individual’s personal name or held jointly with others.  Each form of ownership is subject to specific rules of U.S. income

IRS Announces Expiration of ITINs

Posted on 10/15/16 by Renea M. Glendinning

Since the program began in 1996, a substantial number of Individual Taxpayer Identification Numbers (ITINs) have been issued to nonresident aliens who were not eligible to obtain U.S. social security numbers.  An ITIN must be obtained for the purpose of reporting certain transactions by nonresident aliens that are subject to U.S. income taxation.  These transactions

Frequently Asked Questions Regarding Withholding Requirements Under the Foreign Investment in Real Property Tax Act

Posted on 02/02/16 by Renea M. Glendinning

Previous to the enactment of the Foreign Investment in Real Property Tax Act (FIRPTA) in 1980, foreign sellers of U.S. real estate were not taxed on the capital gains realized on the sale of real estate situated in the U.S., unless such real estate was used in a U.S. trade or business.  Under FIRPTA, foreign

Limited Liability Companies and FIRPTA

Posted on 02/02/16 by Renea M. Glendinning

The Foreign Investment in Real Property Tax Act, known as FIRPTA, subjects a foreign seller of US real estate to a withholding of 15% of the gross sales price.  This withholding is deducted from the net proceeds due to the seller and is required to be remitted to the Internal Revenue Service (IRS) no later

Short Sales and FIRPTA Withholding

Posted on 02/02/16 by Renea M. Glendinning

For some property owners, the mortgage balance owed on their property exceeds its value.  Many of these property owners cannot afford to continue making the mortgage payments. In order to avoid foreclosure, lenders have approved sales of properties for a price that is less than the outstanding mortgage balance. This is referred to as a

U.S. Tax Rules Relating to Foreign Nationals Investing in U.S. Real Estate

Posted on 02/02/16 by Renea M. Glendinning

The rules regarding the U.S. income and estate taxation of foreign nationals are very different from those that apply to U.S. citizens and residents.  It is important that foreign nationals understand the potential U.S. tax implications of investing in U.S. real estate that are applicable to them. The first thing that must be determined is

Foreign Nationals and FIRPTA

Posted on 01/21/16 by Renea M. Glendinning

When a foreign person sells U.S. real estate, he or she is subject to having 15% of the gross sales price withheld from the proceeds received at closing.  This is a requirement under the Foreign Investment in Real Property Tax Act, known as FIRPTA.  This 15% withholding must be remitted to the Internal Revenue Service

What Every Canadian Should Know Before Moving to the U.S.

Posted on 01/21/16 by Renea M. Glendinning

Each year, many Canadians relocate their place of residence by immigrating to the U.S.  By doing so, they become subject to the U.S. tax laws with respect to taxation of income applicable to tax residents.  It is important that these new immigrants understand the obligations associated with U.S. income tax reporting and disclosure requirements. U.S.

Are You a U.S. Income Tax Resident and Don’t Know It?

Posted on 12/07/15 by Renea M. Glendinning

You can be taxed for U.S. income tax purposes either as a resident or as a nonresident.  Residents are required to report their worldwide income to the U.S. taxing authorities.  Nonresidents are required to report only income arising from U.S. sources. There are several ways you can be treated as a resident for U.S. income

U.S. Resident and U.S. Citizen Services

Navigating the perilous waters of cryptocurrency reporting

Posted on 05/14/19 by Annamaria Kiss

As the hot topic in the world of investments, cryptocurrencies have been making waves in the financial markets for some time. During the early years, countless people were attempting to figure out whether cryptocurrencies presented a once-in-a-lifetime opportunity or the next bubble to burst akin to the dot-com craze of the late 1990s. The ever

So, you want to move to Hungary?

Posted on 02/06/19 by Annamaria Kiss

Have you received an offer for a foreign work assignment in Hungary? Did your parents or grandparents hail from Hungary and you always wondered about reconnecting with your roots? Are you contemplating spending your retirement years in Hungary where your money can stretch further? If you answered yes to any of these questions, this article

Are you a U.S. Citizen or U.S. Resident investing abroad? You may need to re-evaluate your investment strategy.

Posted on 02/05/19 by Phoebe Trumpler, CPA

Investing Abroad is Complicated for U.S. Tax Purposes U.S. Citizens including U.S. Expatriates (expats) and U.S. Permanent Residents need to be aware of the U.S. tax ramifications of investing in non-U.S. mutual-type funds abroad, and seriously consider avoiding these investments. By understanding the tax and reporting cost issues associated with these investments, referred to as

Helping Hungarians with FATCA Disclosures

Posted on 01/04/19 by Annamaria Kiss

Hungary was the first country in the central European region to join forces with the United States to implement the Foreign Account Tax Compliance Act, also known as FATCA. The agreement between the Hungarian and the U.S. government sets out to achieve bilateral reporting of foreign financial accounts, such as bank accounts, as of January

The New Deduction for Foreign Derived Intangible Income

Posted on 08/08/18 by Christina Greenstein, CPA

Background The 2017 Tax Cuts & Jobs Act made many fundamental changes in the area of International Taxation. One of the international provisions, Sec. 250, provides for a reduced rate of tax on sales of products and services to foreign customers of U.S. domestic corporations. Known as the Foreign Derived Intangible Income deduction, or FDII deduction,

Global Intangible Low-Tax Income

Posted on 08/08/18 by Chris Corneroli, CPA

In an effort to minimize the shifting of corporate profits to low-tax countries, the Tax Cuts and Jobs Act of 2017 (TJCA) introduced a new category of foreign income called the “global intangible low-tax income”, or GILTI. GILTI is essentially a minimum tax on foreign earnings that applies to all U.S. shareholders – individuals who

Are You Reporting Non-U.S. Income and Assets?

Posted on 06/26/18 by Phoebe Trumpler

If you are a United States citizen or tax resident living in the U.S. or abroad an Expatriate or Expat, you are required to file a U.S. income tax return to report to the IRS any income that you earn or receive from both inside and outside of the United States.  This includes but is

Living and working abroad requires special attention at tax time

Posted on 03/14/18 by Phoebe Trumpler, CPA

If you are a U.S. citizen or U.S. permanent resident living abroad (the Expatriate or Expat), you have several tax opportunities to be aware of. While you will be taxed on your worldwide income, you may be able to exclude up to $105,900 (for 2019) of your foreign wages or self-employment net income from your

Foreign Pension Plans

Posted on 03/14/18 by Phoebe Trumpler, CPA

With today’s global footprint, many U.S. taxpayers have pensions from employment in other countries. A pension plan that is in another country may not have the same tax benefits in the U.S. as it does in the other country. Unfortunately, this can lead to an unwelcome surprise in terms of U.S. income tax and foreign

What does the Tax Cuts and Jobs Act mean to international tax filers?

Posted on 02/21/18 by Phoebe Trumpler, CPA

The Tax Cuts and Jobs Act (TCJA) of 2017 brings about changes to many fundamental aspects of US international taxation, some of which could present significant additional burdens to US taxpayers including U.S. Expatriates (Expats). The following is a brief overview of some of the changes to be aware of when dealing with international tax

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