The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more
The curiously titled "Heroes Earnings Assistance and Relief Tax Act of 2008" became law 17 June 2008. This was the third major revision of expatriation rules in 12 years. While the Act provides laudable benefits to armed...more
As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more
Most people who are born in the United States or who purposely become citizens here know they are U.S. citizens. But many people who’ve spent their lives abroad and are citizens of other countries may be shocked to learn that...more
Recognizing that expatriate group health plans may find it impossible, or nearly impossible, to comply with all of the relevant provisions of the Patient Protection and Affordable Care Act of 2010 (PPACA), the U.S. Labor...more
Last fall, when Hugo Chavez won re-election as President of Venezuela, more and more Venezuelans were expected to move here to South Florida. And they have....more
Code §2501(a)(2) provides that, except as to certain expatriates, U.S. gift taxes do not apply to the transfer of intangible property by a nonresident not a citizen of the United States. This exemption is big enough to drive...more
Code §2801 imposes U.S. transfer taxes on transfers by former U.S. persons who have expatriated if the transfer is to a U.S. person. This tax is imposed on the U.S. recipient. A recent article by Joseph Toce, Jr. and Joseph...more
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