Expatriates

News & Analysis as of

The Hidden Cost Of “Going Home” — the Expatriation Tax for Long-Term Permanent Residents Who Return to Their Home Countries

People immigrate to the United States for many different reasons. Many come here for work reasons and, somewhere along the way, obtain permanent resident status, otherwise known as holding a “green card.” They may work in the...more

Marital Deduction Trusts and Expatriates – More Questions Than Answers

If an expatriate dies and leaves property to a U.S. citizen or resident spouse, can a marital trust be used to defer or avoid the transfer tax imposed under Section 2801? Both the Code and the Regulations seem to say yes, but...more

Saudi Arabia Update – April 2016

Legal Developments - New incentives for achieving Saudization requirements - The Human Resources Development Fund (HRDF), which is an affiliate of the Ministry of Labor (MOL), has proposed a new system to reward...more

U.S. Expatriates Eligible to Open State Department Federal Credit Union Accounts

Due to a combination of factors, including increased enforcement of U.S. anti-money laundering and trade sanction laws and fear of securities law violations, a number of U.S. financial institutions have closed out existing...more

Expatriation Case

Cases on the new expatriation regime under Code Section 877A are few and far between. The Tax Court has now issued an opinion involving a U.S. resident who gave up his green card and the resulting consequences under Code...more

Saudi Arabia Update - February 2016

Legal developments - Local partner requirement reported to cease - Saudi Arabia seeks to draw investors to help reduce its reliance on oil exports and aims to facilitate foreign companies' investment in its market....more

Japan: Decision-Making & Maintaining Harmony

Japan’s surprise move to cut interest rates below zero last month brought its continuing economic challenges back into the global limelight. The country remains an economic and industrial powerhouse -- currently ranked the...more

DOJ’s Latest Offshore Tax Case Shows Expatriates Who Renounce U.S. Citizenship Not Immune From Prosecution

An individual residing in Switzerland since 2007, who apparently renounced his U.S. citizenship four years ago, was convicted today in federal court of one count of filing a false U.S. income tax return. According to a...more

What do we need to know to comply with the new proposed Section 2801 regulations?

Section 2801 imposes a tax on covered gifts and covered bequests received by U.S. citizens or residents from a covered expatriate. Section 2801 also applies to domestic trusts and foreign trusts electing to be treated as...more

Thoughts for U.S. Employers Sending Employees Overseas

“At will” employment is a US thing: First step is to recognise that “at will” employment is not generally recognised outside the US. Employees working overseas will almost always have an employment contract (whether or not...more

Way, Way Back: Retroactivity in the Proposed 2801 Regulations

Individuals who relinquished U.S. citizenship since 2008 may find themselves with U.S. tax exposure for gifts they made before they expatriated under proposed regulations announced by the IRS. Under the current expatriation...more

Retiring Abroad: The Lure of the Exotic, the Chore of U.S. Tax Compliance

For anyone who has watched the movie “The Best Exotic Marigold Hotel,” the idea of retiring overseas may be tempting. Glamorous locales exist around the world with warm sands, fragrant breezes and stunning sunsets where...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

Successful Strategies for Doing Business in Asia: Vietnam (Updated)

WHAT ROLE WILL THE GOVERNMENT OF VIETNAM PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Ministry of Planning and Investment (MPI) is the central administrative body that oversees all investment...more

Successful Strategies for Doing Business in Asia: Thailand (Updated)

WHAT ROLE WILL THE GOVERNMENT OF THAILAND PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Thai government regulates foreign direct investment by requiring foreign investors to obtain approval from the...more

Giving Up U.S. Citizenship - Estate and Gift Tax Traps

It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to...more

New IRS Regs Escalate Tax Consequences of Renouncing Citizenship or Surrendering Green Card

On September 9, 2015, the IRS released long-awaited proposed regulations under Internal Revenue Code (Code) section 2801, which imposes a tax on the recipient of a gift or bequest from certain individuals who relinquished...more

Successful Strategies for Doing Business in Asia: Taiwan (Updated)

WHAT ROLE WILL THE GOVERNMENT OF TAIWAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Three types of Taiwan government approval requirements may be relevant to direct foreign investment in Taiwan: •...more

Tax-Savvy Planning for Foreign Business Owners Seeking Temporary U.S. Residence: Alternatives to the EB-5 Visa

The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the...more

International News: Focus on Private Equity

Our Focus on Private Equity provides a global perspective on some of the challenges being faced by PE firms and how these can be successfully addressed. It also examines some of the many opportunities available, e.g., by...more

Successful Strategies for Doing Business in Asia: Singapore (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF SINGAPORE PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? REGISTRATION REQUIREMENT - Save for the restrictions discussed under Question 5, there is generally no...more

Saudi Arabia update - August 2015

Legal Developments - Expatriate Workers Restricted from Certain Job Categories - As part of Saudi Arabia’s ongoing Saudization campaign, the Ministry of Labor (MoL) identified this month 19 jobs that are restricted...more

The “Reed Amendment” and Admissibility to the United States: Will I Be Barred From Reentry After Renunciation?

A common concern about renunciation of U.S. citizenship is that of admissibility to the United States thereafter. Many people tell me that they have read about a permanent ban on reentry to the United States following...more

Successful Strategies for Doing Business in Asia: Korea (Updated)

WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more

Successful Strategies for Doing Business in Asia: Indonesia (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF INDONESIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The existing Indonesian Investment Act is Law No. 25 of 2007, passed by the Indonesian House of Representatives...more

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