Tax Savings Available With Pre-Immigration Planning

Law360 (October 16, 2018, 4:20 PM EDT) -- As most practitioners are aware, United States nonresident aliens — that is, individuals who are neither citizens nor residents of the United States — are subject to a far narrower tax scope (both for income and transfer tax purposes) than their United States citizen/resident counterparts (with U.S. citizens and residents referenced as "U.S. taxpayers," herein). Typically, nonresident aliens are taxable by the United States only on income sourced to the country (or, for transfer tax purposes, assets sitused in the United States). In a growingly global world, individuals switch between nonresident alien and U.S. taxpayer classifications with increasing regularity (by, for...

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