Research & publications
Practical perspectives on U.S. trade, tax and cross-border planning.
Articles
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When a Grantor Near Death Buys Back Appreciated Assets From a Foreign Grantor Trust
Why families consider having an ill grantor repurchase appreciated assets from a foreign grantor trust, how Rev. Rul. 85-13 and §1014 make it work for a U.S.
Cynthia Wu · 6 min read -
IRC §684: When a Transfer to a Foreign Trust Is Treated as a Sale
Section 684 taxes built-in gain when a U.S. person moves appreciated property to a foreign trust, when a domestic trust becomes foreign, and when a U.S.
Cynthia Wu · 6 min read -
Money Taken From Your Bank Account by a Scammer: When Is the Bank Responsible?
Who bears the loss when a fraudster empties a U.S. bank account depends on how the money left — by check, by consumer electronic transfer, or by wire. The rules, deadlines and first steps for each.
Cynthia Wu · 6 min read -
Structuring Around Gift and Estate Tax for NRAs Holding U.S. Real Estate–ForCoholds USCo
It is common for nonresident aliens (NRAs) to invest in real estate in the United States. However, when they wish to gift this property to their children who reside in the U.S., they can face up to 40% in gift…
Cynthia Wu · 6 min read -
Tax Consequences for NRAs and Foreign Entities: Investing and Liquidating Partnership, LLC, and Corporation Interests
By Cynthia When nonresident aliens (NRAs) and foreign entities invest in U.S. entities, the tax consequences upon liquidating their interests can vary significantly based on whether the investment is in a…
Cynthia Wu · 7 min read -
Pre-Immigration Tax Planning: What to Do Before You Become a U.S. Tax Resident
When U.S. tax residency starts, why estate tax domicile is a separate question, and the steps worth taking before the move: realizing gains, gifts, trusts and the five-year rule, foreign companies and funds…
Cynthia Wu · 6 min read -
Investment and Inheritance: Can a Nonresident Use a U.S. Revocable Trust and LLC?
What a U.S. living trust holding an LLC does — and does not do — for a nonresident alien: probate, income tax by LLC classification, estate tax on U.S.-situs assets, gifts, and the filings that come with it.
Cynthia Wu · 6 min read -
Setting Up a U.S. Irrevocable Trust That Owns an LLC for a Nonresident Grantor
How a U.S. irrevocable non-grantor trust funded by a nonresident alien with foreign assets is taxed: trust tax rates and NIIT, dividends versus rent, California trust rules, gifts, estate tax and basis.
Cynthia Wu · 6 min read -
Tax Consequences for Foreign Trusts
Understanding the tax consequences for trusts, particularly distinguishing between US (domestic) and foreign trusts, is essential for effective tax and estate planning.
Cynthia Wu · 9 min read -
Tax Consequences for Nonresident Aliens Owning U.S. Real Estate
How rent, sale, gifts and death are taxed when a nonresident alien owns U.S. property: the 30% rule and the §871(d) election, FIRPTA withholding, California withholding, the $13,000 estate tax credit, and a…
Cynthia Wu · 6 min read
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