Globalization is an important factor in today’s tax planning. International assignments for US executives, children studying abroad, and families with multiple citizenships and residencies mean that taxpayers and their advisors need to be increasingly aware of cross-border considerations in their tax planning and compliance.
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In today’s environment the focus on the disclosure, reporting, and taxation of foreign assets has sharpened.
Accidental citizen: The unintended consequence of adding vacation time to a foreign work assignment
An individual visiting the US temporarily for a short-term work assignment may inadvertently become a US resident under the "physical presence" test by extending the stay. For individuals contemplating moving to or spending time in the US, it is vital that they seek pre-immigration advice in order to mitigate potentially unwelcome tax consequences.
Residency test: What makes a person a US resident for purposes of the US transfer tax?
An individual will be considered domiciled in the US if the person is living there and intends to stay indefinitely. When assessing an individual’s intent to remain permanently in the US, the courts consider a variety of factors.