The interaction of U.S. rules with the tax laws of a taxpayer’s home country need to be carefully assessed based on the personal circumstances of the individual. Another important issue is the international tax laws under the Internal Revenue Code which can apply to foreign companies or trusts. Often this means that individual’s moving to America need to be mindful of how America’s laws will treat their home country’s assets and structures and increase the compliance costs associated with such entities.
For expat entrepreneurs and executives in America, the additional burden of tax return requirements in the U.S. for assets in their home country can create a real risk of double taxation unless a proper advice is obtained.
Section 6048 requires US taxpayers to make an...
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