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The U.S. Private Client Tax Services Legal Practice focuses on providing high-level tax counsel to affluent individuals and their enterprises with international financial ties. This service is essential for clients with a U.S. connection, such as an American living in the Philippines or a local family holding U.S. property. The practice involves developing advanced strategies for cross-border tax planning, tailored to the distinct situations of U.S. expatriates, who are subject to tax on their global income, and foreign nationals, who are taxed on their U.S.-based assets and income. The primary objectives are to mitigate exposure to U.S. income, gift, and estate taxes, optimize the structure of international assets, and guide clients through mandatory disclosure requirements like FATCA.
U.S. private client tax services are bespoke advisory services designed to help individuals and families manage their U.S. tax obligations. Unlike standard tax preparation, these services focus on strategic planning related to U.S. income, gift, and estate taxes, particularly in a cross-border context. This involves structuring international investments and business interests to be tax-efficient and planning the transfer of wealth across generations in a way that minimizes global tax exposure.
Yes. The United States operates on a system of citizenship-based taxation, which is unique among major countries. This means that all U.S. citizens and permanent residents are required to file a U.S. federal tax return every year and report their entire worldwide income to the Internal Revenue Service (IRS), regardless of where in the world they live or earn their income. Tax treaties and foreign tax credits often help prevent double taxation on income also taxed by another country.
Non-U.S. citizens who are not residents of the U.S. are typically subject to U.S. tax only on income that is sourced from within the United States. This includes wages from U.S. employment, income from a U.S. trade or business, and rental income from U.S. real property. Additionally, they may be subject to a U.S. estate tax upon their death, but this tax generally applies only to the value of their assets that are considered to be situated in the United States.
FATCA, the Foreign Account Tax Compliance Act, is a U.S. law designed to combat offshore tax evasion. It primarily affects U.S. persons by requiring foreign financial institutions, such as banks and brokerage firms, to report information about financial accounts held by their U.S. clients directly to the IRS. It also imposes a direct reporting requirement on U.S. taxpayers themselves, who must disclose their foreign financial assets on their annual tax returns if the value exceeds certain thresholds.
For foreign nationals who are not U.S. residents, the U.S. gift and estate tax has a limited scope. It generally applies only to transfers of their U.S.-sited assets. This includes U.S. real estate, tangible personal property located within the U.S., and securities issued by U.S. corporations. It is important to note that the lifetime tax exemption for foreign nationals is significantly lower than the exemption for U.S. citizens, which makes proactive tax and estate planning crucial.
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