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Section 2801: Identifying Covered Expatriates
Episode 1949
One of the most difficult aspects of Section 2801 of the
Internal Revenue Code is not calculating the tax—it’s determining whether it applies at all.…
5 months, 2 weeks ago
Interaction of Section 2801 and US Gift/Estate Tax
Episode 1948
One of the most important safeguards in the U.S. transfer tax system is this:
👉 Section 2801 is not meant to overlap with the regular gift and estate …
5 months, 2 weeks ago
Timing of Section 2801 Tax Liability
Episode 1947
One of the most critical—and often misunderstood—questions under Section 2801 of the
Internal Revenue Code is:
👉 When is the tax actually triggered?
Th…
5 months, 2 weeks ago
Mainland-Born Puerto Rico Residents and Estate Tax
Episode 1946
Puerto Rico’s estate tax rules can look similar on the surface—but where you were born matters more than most people expect.
⚖️ 1️⃣ The Key Distinctio…
5 months, 3 weeks ago
Taxable Assets for Puerto Rico Domiciliaries
Episode 1945
For individuals domiciled in Puerto Rico, U.S. estate tax follows a hybrid system under the
Internal Revenue Code—similar in many ways to the treatme…
5 months, 3 weeks ago
Estate Tax Rules for Puerto Rico Residents
Episode 1944
Puerto Rico occupies a unique position in the U.S. tax system—and that uniqueness extends to estate tax treatment.
⚖️ 1️⃣ A Hybrid Regime
Under the
Int…
5 months, 3 weeks ago
Prorated Credit Calculation for Estate Tax
Episode 1943
For non-resident aliens (NRAs), estate tax treaties can unlock a powerful benefit:
👉 Access to a prorated share of the full U.S. unified credit
Instead…
5 months, 3 weeks ago
Estate tax treaties can boost the NRA exemption via a prorated unified credit—if conditions are met. ⚖️
Episode 1942
The standard rule for non-resident aliens (NRAs) is harsh:
• Only a $60,000 exemption
• Based on a $13,000 unified credit
But in some cases, tax treati…
5 months, 3 weeks ago
NRA Estate Tax Exemption Explained
Episode 1941
When it comes to U.S. estate tax, non-resident aliens (NRAs) face one of the most restrictive regimes in the world.
⚖️ 1️⃣ The Core Rule
Under the
Inte…
5 months, 3 weeks ago
Domicile Explained for Green Card Holders
Episode 1940
A common assumption is that holding a U.S. green card automatically makes you domiciled in the United States for estate tax purposes.
👉 That’s not qui…
5 months, 3 weeks ago