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US Tax Planning

20 October 2004 / Lee Williams , Rick Layman , Dawn Nicholson
Issue: 3980 / Categories: Comment & Analysis
LEE WILLIAMS, RICK LAYMAN, and DAWN NICHOLSON tell new immigrants to the USA how to minimise their income tax liabilities.

Am I There Yet?

MOVING FROM ONE country to another can offer some spectacular tax planning opportunities — often the chance to leave one tax jurisdiction but structurally insulate one's assets and/or income from tax in the new country. In an imperfect tax world pre-immigration planning exploits these opportunities to 'fall between the cracks' and sometimes creates nightmares for those who dream of global taxation of us all somewhere.

Broadly speaking planning for the US rules for transfer taxes on gifts etc. depends on the taxpayer's domicile. The domicile rules whilst resembling those of other common law countries have some peculiarities that are unique to the US. These details and the implications for transfer taxes cannot be dealt with in this article but are covered in full in our book US/UK Private Wealth Tax Planning....

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