Justin Brown, left, and Brittany Yodis, right, with Ballard Spahr. Courtesy photos International Income and Estate Tax Planning for Cross-Border Clients
The United States has specific income tax rules for noncitizen nonresidents (NCNRs), and it has an entirely different estate and gift tax regime for NCNRs, creating traps for the unwary cross-border client.
May 03, 2023 at 11:52 AM
7 minute read
As noncitizens and nonresidents of the United States have increasingly acquired global assets, they may unknowingly be subjecting themselves to various income and transfer tax laws across multiple jurisdictions. The United States has specific income tax rules for noncitizen nonresidents (NCNRs), and it has an entirely different estate and gift tax regime for NCNRs, creating traps for the unwary cross-border client.
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