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US Gift Tax Rules for Non-Resident Aliens
Episode 1931
The U.S. gift tax system treats non-resident aliens (NRAs) very differently from U.S. citizens. Understanding this distinction is key for cross-borde…
6 months, 1 week ago
Unresolved Issues Under Section 2801
Episode 1930
Section 2801 of the
Internal Revenue Code introduced a powerful regime for taxing transfers from covered expatriates—but several key areas remain unc…
6 months, 1 week ago
Deducting Section 2801 Tax on Distributions
Episode 1929
When U.S. beneficiaries receive distributions subject to Section 2801 of the
Internal Revenue Code, a natural question arises:
👉 Can the §2801 tax be …
6 months, 1 week ago
A Foreign Trust Electing To Be Treated As A Domestic Trust For Section 2801 Purposes
Episode 1928
Foreign trusts receiving transfers from a covered expatriate face a critical choice under Section 2801 of the
Internal Revenue Code:
👉 Elect to be tr…
6 months, 1 week ago
Powers of Appointment Under Section 2801
Episode 1927
Section 2801 of the
Internal Revenue Code does not only apply to direct gifts or inheritances—it also captures indirect transfers through powers of a…
6 months, 1 week ago
Covered Transfers to Trusts Explained under Sec 2801
Episode 1926
When assets are transferred from a covered expatriate into a trust, Section 2801 of the
Internal Revenue Code applies—but the tax treatment depends h…
6 months, 1 week ago
Qualified Disclaimers Under Section 2801
Episode 1925
In cross-border estate planning involving covered expatriates, one often-overlooked tool is the qualified disclaimer. When properly executed, it can …
6 months, 2 weeks ago
Foreign-Situs Limits Under Section 2801
Episode 1924
• Certain relief mechanisms—such as spousal exclusions via trust elections—
👉 are limited to U.S.-situs assets
This means:
• Foreign assets may not ben…
6 months, 2 weeks ago
Spousal Exclusion Under Section 2801
Episode 1923
Section 2801 of the
Internal Revenue Code imposes tax on certain gifts and inheritances received from covered expatriates. However, an important exce…
6 months, 2 weeks ago
Understanding Covered Gifts and Bequests
Episode 1922
When dealing with cross-border transfers from former U.S. citizens or long-term residents, Section 2801 of the
Internal Revenue Code introduces a uni…
6 months, 2 weeks ago