Droit Fiscal Américain
U.S. Exit Tax and Swiss Occupational Pension Plans (LPP)
Renouncing U.S. citizenship may trigger significant Exit Tax exposure, particularly on Swiss LPP pension capital. Understanding IRC §877A and Covered Expatriate rules is essential for international wealth planning.
U.S. Estate Tax and Prior Gifts: A Critical Risk in International Estate Planning
How prior lifetime gifts can impact U.S. Estate Tax calculations and treaty credit planning for European investors and family offices.
Gift Tax Implications for U.S. Citizen Spouses Giving to Non-U.S. Citizen Spouses
U.S. citizens gifting to non-U.S. citizen spouses face limits: no unlimited marital deduction, and only $190,000 (2025) excluded annually. Gifts above require Form 709. Proper planning helps avoid gift tax and ensure compliance.
𝐄𝐬𝐭𝐚𝐭𝐞 𝐨𝐟 𝐑𝐨𝐰𝐥𝐚𝐧𝐝 𝐯. 𝐂𝐨𝐦𝐦𝐢𝐬𝐬𝐢𝐨𝐧𝐞𝐫, 𝐓.𝐂. 𝐌𝐞𝐦𝐨 𝟐𝟎𝟐𝟓-𝟕𝟔
The Rowland case underscores strict compliance for DSUE portability elections—timely, complete Form 706 filings are essential; safe harbor and equitable relief can’t cure late or incomplete submissions.
