Research & publications
Original publications
Articles
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Understanding FBAR Violations: Non-Willful, Willful, and Criminal Penalties
The Report of Foreign Bank and Financial Accounts (FBAR) is a critical compliance requirement for U.S. persons with foreign financial accounts. Failure to file an FBAR or filing inaccurately can result…
Cynthia Wu · 5 min read
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Understanding FBAR Penalties
The Report of Foreign Bank and Financial Accounts (FBAR) is a critical compliance requirement for U.S. persons with foreign financial accounts. Failure to file an FBAR or filing inaccurately can result in…
Cynthia Wu · 5 min read
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Unveiling Bank Accountability: A Case Study of Fund Transfers induced by Scam
Unveiling Bank Accountability: A Case Study of Fund Transfers induced by Scam By Cynthia Wu Hello, Attorney Wu. The situation is as follows: The interviewee is a user in New York…
Cynthia Wu · 11 min read
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Structuring Around Gift and Estate Tax for NRAs Holding U.S. Real Estate–ForCoholds USCo
By Cynthia Introduction 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…
Cynthia Wu · 6 min read
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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…
Cynthia Wu · 4 min read
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Pre-Immigration Tax Planning for Chinese Expatriates Moving to the U.S.
By Cynthia Wu Pre-immigration tax planning is crucial for Chinese expatriates moving to the United States to minimize their federal and state tax liabilities. This article explores the intricacies of…
Cynthia Wu · 19 min read
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Investment and Inheritance: NRAs Using Revocable Trusts with US LLCs
By Cynthia Wu The income tax treatment for an NRA (Non-Resident Alien) grantor of a US LLC holding non-US assets depends on the nature of the income and the relationship…
Cynthia Wu · 12 min read
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Setting Up a Domestic Irrevocable Trust with LLC Ownership for an NRA
By Cynthia Wu Setting up a trust can be an excellent strategy for Non-Resident Aliens (NRAs) to manage and protect their assets, considering future uncertainties for beneficiaries, such as divorce, bankruptcy,…
Cynthia Wu · 7 min read
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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. The US taxation of a trust’s income, gains,…
Cynthia Wu · 9 min read
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Tax Consequence for Nonresident Aliens (NRAs) Owning U.S. Real Estate
By Cynthia Wu Often, I have nonresident alien clients who come to me for estate planning. In most situations, U.S. real property is involved. Some NRA clients want estate planning to…
Cynthia Wu · 10 min read
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