A non-U.S. citizen client became a U.S. tax resident in 2020 after qualifying as a nonresident under the closer-connection exception in 2018 and 2019. Although she filed Form 1040 for 2020, the return omitted international filings tied to a Jersey trust and its foreign company.
Read MoreAn Australian couple planned a two-to-four-year U.S. move. One spouse was a U.S. citizen; the other was a nonresident who owned a property company, consulting company and family home. U.S. residency would bring those assets and worldwide income into the U.S. tax net.
Read MoreA U.S. citizen living abroad wholly owned a Singapore operating company that distributed products throughout Asia. The client's spouse also worked in the business through a Thailand cost-plus company. With projected annual pre-tax profits of SGD 890,000 - approximately $712,000 - the existing structure created substantial exposure under the U.S. controlled foreign corporation rules.
Read MoreA non-U.S. individual approached Expat Tax Professionals before moving from Singapore to the United Kingdom. She had recently become eligible to withdraw approximately $175,000 from a U.S. 401(k) without an early-distribution penalty and expected to qualify for the UK's four-year Foreign Income and Gains (FIG) regime.
Read MoreA U.S. citizen living in New Zealand operated a legal-recruitment business serving U.S. law firms through a New Zealand company that wholly owned a U.S. LLC. With projected net profits of approximately $500,000 a year, the structure appeared straightforward but produced a severe mismatch between U.S. and New Zealand tax rules.
Read MoreA married Australian/Japanese couple approached Expat Tax Professionals as they prepared to sell their Massachusetts home, relocate to Australia and relinquish U.S. green cards held since 2010. Because they had been permanent residents for more than eight of the prior fifteen years, surrendering their green cards would be an expatriation for U.S. tax purposes.
Read MoreA dual U.S./New Zealand couple approached Expat Tax Professionals after relocating to the United States. They had consistently filed U.S. tax returns and disclosed their foreign financial accounts, but their prior filings had not properly addressed the complex U.S. tax treatment of two New Zealand retirement plans held for more than a decade.
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