[ Offshore Tax ] Does the IRS Tax All Foreign Assets of Wealthy Immigrants?
Strategies often used in US Pre-Immigration Tax Planning:
PFIC Mitigation: This strategy aims to avoid punitive taxation on certain non-U.S. investments like mutual funds, life insurance policies, or pension plans that may be classified as Passive Foreign Investment Companies (PFICs). Holding passive assets through offshore corporations does not easily defer passive income due to U.S. anti-deferral rules. However, certain variable life insurance products can defer income, potentially avoiding U.S. income and estate taxes if structured correctly. PFICs are foreign corporations meeting specific criteria, and many foreign mutual funds, pension funds, money market accounts, and some REITs could fall under this category.
Accelerating Income: This strategy prioritizes realizing non-U.S. source income while deferring losses and deductible expenses. Accounts receivables, stock options, accumulated earnings from foreign entities, taxable deferred compensation plans, and notes from installment sales, are collected. Attention should be given to assets with substantial built-in gain.
Basis Step Up: To minimize U.S. taxation on appreciated assets acquired before moving to the U.S., individuals use a planning technique with no tax consequences in their country of origin. Engaging in a transaction before relocating to the U.S. treats it as a sale of the property for U.S. tax purposes while remaining non-taxable for foreign country purposes.
Foreign Tax Credit: For business holdings in high-tax jurisdictions outside the U.S., this strategy addresses double taxation. Earnings are first taxed in the foreign jurisdiction and again in the U.S. (at a fixed corporate rate of 21% and a maximum rate of 37% for individuals) upon distribution to the U.S. resident. Certain structures allow the U.S. resident to credit the foreign taxes paid against their U.S. taxes, eliminating U.S. taxation on foreign earnings. Treating a foreign entity as a disregarded entity for U.S. tax purposes, individuals credit the foreign taxes paid against their U.S. income taxes on the same foreign income.
Qualified Dividends: This strategy is suitable for business holdings in low-tax jurisdictions. It involves repatriating earnings through a qualifying treaty country, subjecting the earnings to lower taxation rates (rather than higher ordinary rates of up to 37%) and avoiding certain U.S. taxes.
Trusts: Finally, we help individuals establish trust before moving to the United States. A trust is a legal structure that holds assets in the name of the trust rather than the individual transferring the assets. The earnings are distributed to the person(s) designated in the trust. Asset protection, probate avoidance, and estate tax blockers are not typically considered tax plays.
TIMESTAMPS:
0:00 INTRO
0:36 Income-producing assets
1:11 Capital gain taxation
1:38 Outro
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