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dlukton
Nomad Capitalist
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Comments by "dlukton" (@dlukton) on "New US Expat Tax Numbers for 2022" video.
Citizenship-based taxation was not a "temporary" measure; it comes from the 16th Amendment (together with a subsequent SCOTUS decision on the meaning of the 16th Amendment). "Congress shall have power to lay and collect taxes on incomes, FROM WHATEVER SOURCE DERIVED"
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Most likely the "stepped up basis cost" provision of the tax code would apply; and so if you renounced your citizenship soon after inheriting the assets within the trust, you would owe little or nothing to the IRS (at least with respect to the assets that had been held in the trust).
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@Timithos nothing illegal about "thinking out loud".
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Yeah, I think that Hamza is probably correct. However, if you set up a corporation in a country with zero corporate tax/zero income tax, and put your assets in the name of the corporation, and then "pay yourself a salary" and then file taxes under the FEIE, you might be able to save SOME money in taxes, provided also you were residing in a country that is optimized for this strategy. (You'd still have to pay a self-employment tax if the assets were held by an LLC, and everything you're doing would have to be reported to the IRS)
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@patienceisalpha I'm no expert on trusts, but I think there's a way to set it up so as to avoid taxes if the trust is put in the name of a trustee (a trustee other than the "true owner") and if the "true owner" of the trust is not named as the prime beneficiary. Basically, if the trust is set up so that the trustee could legally run off with the money, then taxes can be avoided. But then, one would have to really, really trust the trustee in that situation.
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@patienceisalpha My comment was about trusts, not corporations. And with respect to trusts, the essence of my comment was that one could avoid US taxes by entrusting a trustee with the money (i.e., trusting him to refrain from stealing all the money).... which is not something that I would do.
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Having a lot of money in an IRA could make it nearly impossible for a person to AVOID being a a covered expatriate. For example, if a person has $800K in an IRA, and takes out $200K per year for four years in a row before renouncing, he's going to be a covered expat.
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