Naturalization does not raise the estate tax exemption of a green card holder who already lives in the United States. It changes the treatment of transfers from a spouse, the reach of the estate and gift tax treaties, the taxation of income after a move abroad, the status of minor children and the cost of leaving the United States tax system again.
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Summary A person who is neither a United States citizen nor domiciled in the United States is taxed at death on United States situs property alone, but against an exemption of only $60,000 and a top rate of 40 percent. The exemption for a citizen or a domiciliary in 2026 is $15,000,000. Situs is decided asset by asset, and the
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The primary purpose of marital agreements is to settle the questions of separation of assets and alimony in case of a divorce. Such an agreement can be made prior to a marriage (premarital or prenuptial agreement) or during the marriage. Marital agreements may also provide for an alternative inheritance structure that even allows spouses to omit each other from their
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Summary Asset protection is the arrangement of title, insurance, entities and trusts before any claim arises. It is lawful only while the client is solvent, before a claim is foreseeable, and with full tax reporting. Every transfer remains subject to voidable transfer law and the Bankruptcy Code. Transfers to a self-settled trust made with intent to hinder creditors can be
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