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Discussion about current events, culture, independent candidates, business, education, travel, death and taxes, global mobility, citizenship and residence by investment options, Americans abroad, FATCA, CRS, U.S. citizenship renunciation, Green Card abandonment, citizenship taxation, PFIC, GILTI, foreign trusts, I-407 and more ...
Episodes
Thursday Mar 16, 2023
Thursday Mar 16, 2023
March 16, 2023 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @Expatriationlaw
On March 16, 2023 Virginia La Torre Jeker published a post titled:
The Perfect Storm - U.S. Tax, Community Property and The Mobile International Couple
"Once upon a time:
Two UK nationals who were married were exiled from Uganda, moved to Belgium (a community property jurisdiction). The husband had substantial U.S. stock registered in his name. He died and an estate tax was owed to the IRS."
This case combines elements of:
- how the U.S. estate tax applies to U.S. situs assets owned by individuals who are neither U.S. citizens nor domiciled in the U.S.
- the difference between ownership of assets in a community property jurisdiction (Belgium) and a separate property jurisdiction (U.K.)
- how "conflict of law rules" will determine which jurisdiction's law applies to determine property ownership.
The couple did NOT "Live Happily Ever After!
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