income tax Archives | Page 2 of 2

By Anthony Diosdi As discussed in previous articles, the determination of an individual’s residency status for U.S. income tax purposes is different than the determination of an individual’s residency status for U.S. estate and gift tax purposes. A U.S. citizen or a resident alien is subject to U.S. income tax on his or her worldwide income. An individual becomes a resident alien by violating the so-called “substantial presence test” or obtaining lawful permanent resident status (obtaining a Green Card). A nonresident alien is subject to U.S. income tax on certain passive income that is sourced in the United States and income that is effectively connected with the conduct of a U.S. trade or business. A U.S. citizen or a resident alien domiciliary is subject to U.S. estate and gift tax…

By Anthony Diosdi Many U.S. income tax questions arise in connection with receipt of inherited property. These questions generally include whether the recipient must include the value of such property in gross income for U.S. income tax purposes and what will be the U.S. income tax consequences of the recipient’s subsequent disposition of the inherited property. This article will briefly summarize the more relevant U.S. income tax consequences in connection with inherited property with emphasis on property inherited from a foreign individual. Anyone reading this article must be aware that the U.S. also has a transfer tax regime that could impose an estate tax upon the transfer of property of a decedent. However, the estate tax is generally imposed on the estate of a decedent and not on the recipient.…

Tag: income tax

Violation of a Temporary Visa and the Possible Effect on “Domicile”

Income Tax Considerations of Property Inherited from A Foreign Person