On April 26, 2022 Creative Planning (Formerly Thun Financial) ran a webinar on PFICs. What follows is a link to the webinar.
PFIC – April 2022
https://attendee.gotowebinar.com/recording/6339022506851871235
Today’s post, Part II, was written by Virgina La Torre Jeker, J.D. and John Richardson, J.D.
Part I of this blog post discussed President Biden’s Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death. To recap, the major thrust of the Green Book proposal (starting at page 30) is to treat gifts and bequests as “deemed sales at fair market value” triggering a capital gains tax which would be payable with respect to the year of the transfer. The net investment income tax / 3.8% surcharge looks as if it can certainly apply in addition to the capital gains tax (full detail on the 3.8% surcharge is here). The Green Book contains no proposals to eliminate or change the current Estate and Gift Tax rules and we believe that taxing gifts and bequests from an income tax perspective while keeping the Estate and Gift Tax regime in place is only a recipe for tax disaster.
Today’s post, Part II, looks at how the proposal will particularly impact the American abroad, its exemptions and carve-outs and how it complicates tax planning for individuals wishing to give up their US citizenship or green card.
Today’s post is in two parts and was written by Virginia La Torre Jeker, J.D. John Richardson, J.D.
On March 28, President Joe Biden released the FY2023 Budget, also known as the Green Book, available here. The Green Book is not proposed legislation, but it might be viewed as a kind of reading of the tea leaves showing what may lie ahead in the not-too-distant future. Today’s post will discuss a Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death.
This is the second time this proposal has been put forth by the Biden Administration. It may be sitting on the shelf for now, but the proposal is an enticing revenue-raiser and helps meet what society has been viewing as a call for a “fairer” tax code, by targeting higher-income and asset wealthy taxpayers. We bet it goes through in one form or another.
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My answer to Can people holding dual/multiple citizenship obtain multiple social security incomes? https://t.co/RmzvhPGRVA
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 12, 2022
Introduction
For many people (including Americans abroad) Social Security programs (whatever they are called in other countries) are an important component of retirement income and financial planning.
During December 2021 I had the good fortune to host Dan Mazzola on a couple of podcasts. In the first podcast we discuss the inner workings of US Social Security. In the second podcast we discuss financial planning in general.
Here they are …
December 3, 2021 – Smarter Social Security
December 9, 2021 – It’s More About The Investor Than The Investment
Prologue: In search of a tax haven …
Q. What are the best known tax havens? What do you think? A. I strongly advise my clients that the best tax haven, by far, is the ownership of after-tax US dollars. by Andrew Weill https://t.co/BRzjrcC8OX
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 8, 2022
Where to find that tax haven – let’s start with a ROTH IRA
Give your child a jump-start on retirement. Open a Roth IRA as soon as they start earning money to take advantage of compound interest and favorable tax treatment. https://t.co/ZFUDoKH5ps
— GW Carter, Ltd., CPAs (@gwc_ltd) February 25, 2022
The above tweet from CPA Gary Garter leads to a discussion that includes: