Posts Tagged ‘international tax planning’

Facebook Co-Founder Unfriends USA…Now the Empire Strikes Back

May 17th, 2012 by Mark Nestmann

Brazilian-born Facebook co-founder Eduardo Saverin relinquished his U.S. citizenship late last year. As an expatriate, Saverin must pay an “exit tax” on the value of any unrealized gains in his worldwide estate, less a $636,000 exclusion for 2011. I’m not privy to billionaire Saverin’s financial affairs, but I have no reason to doubt his statement [...]

Are You the Property of Your Government?

May 4th, 2012 by P. T. Freeman

As a former U.S. citizen who has given up U.S. citizenship, I’ve visited dozens of countries using my Commonwealth of Dominica passport. One of the most interesting destinations has been the Republic of Cuba. Not being a U.S. citizen makes the process of visiting Cuba much easier. Due to a longstanding U.S. embargo against Cuba, [...]

FATCA: Big Brother Goes Global

April 23rd, 2012 by Mark Nestmann

Sometimes people ask what I fear most. My answer isn’t really what they expect. It’s not riots in central cities, a collapse of food supplies or other essential infrastructure, a terrorist attack, or even the growing U.S. police state. All of these threats are real, but all of them can be dealt with successfully through [...]

New Version of “Billionaire’s Loophole” Now Available

April 19th, 2012 by Mark Nestmann

I’ve just completed the 2012 update to my report The Billionaire’s Loophole. If you’re considering expatriation, you need to read this report. The 2012 edition has some important updates from the 2011 edition, and if you purchased the report in the last year, you’re entitled to a free update. Just log on to your account [...]

Growing Numbers of Tax Refugees Exit USA—Permanently

April 17th, 2012 by Mark Nestmann

If you’re a U.S. citizen or long-term permanent resident (“green card” holder), you have a unique responsibility: you must pay tax on your worldwide income, even if you live outside the United States. Not to mention capital gains tax, gift tax, and estate tax. Numerous additional obligations come with U.S. citizenship or permanent resident status. [...]

Will Mitt Romney Tone Down the U.S. “War on Offshore?”

February 6th, 2012 by Mark Nestmann

I don’t spend much time following the U.S. presidential campaign. My assumption is that every candidate will promptly forget everything he promised as soon as he is inaugurated. This is particularly true if the promise is to limit governmental powers or authority. For instance, candidate Obama promised to close Guantanamo Bay prison, end warrantless wiretapping, [...]

IRS: Offshore Banks Will Need to Disclose Precious Metals Held by U.S. Clients

January 27th, 2012 by Mark Nestmann

Earlier this week, I participated in to a teleconference sponsored by the Society of Trust and Estate Practitioners and the International Law section of the American Bar Association. The conference addressed the expanded offshore asset disclosure requirements brought into effect by the Foreign Account Tax Compliance Act (FATCA). (For background on FATCA  see here, here, [...]

IRS Makes Offshore Voluntary Disclosure Framework Permanent

January 19th, 2012 by Mark Nestmann

U.S. permanent residents and all U.S. citizens, no matter where they live, to declare virtually all offshore accounts with an aggregate value of $10,000 or more. Income generated from these accounts is also taxable. I most recently wrote about these obligations here. U.S. citizens living abroad have a unique reporting burden, as no other civilized [...]

International Living’s Ultimate Event VII–2012

January 14th, 2012 by Mark Nestmann

Mark Nestmann will be a featured speaker and exhibitor at International Living’s Ultimate Event VII to be held Feb. 22-25, 2012 in Cancun, Mexico. The event will be held at the CasaMagna Marriott Cancun Resort. For more information or to register, please see: https://secure.internationalliving.com/CN2121Aweb/W121MA10.

Estate Tax: “Valuation Discounts” Under Attack

December 27th, 2011 by Mark Nestmann

Several proposals now circulating in Congress would crack down on popular estate-planning techniques.  The one the IRS—and tax-loving congressional representatives—dislike the most are “valuation discounts” associated with family limited partnerships and related entities.  The IRS has fought valuation discounts tooth and nail, but the courts have, with some exceptions, generally upheld them as reflecting market [...]

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