Immigrating to the USA: effective wealth planning Charles P LeBeau, Attorney, San Diego, California, USA

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1 Immigrating to the USA: effective wealth planning Charles P LeBeau, Attorney, San Diego, California, USA Although considerations will vary widely depending on the circumstances of the specific non-resident alien (NRA) in question, the essential point is that any planning should be done before the NRA enters the US tax system. Flexibility is greatly reduced after this event occurs, and subsequent transfers may be subject to a variety of income tax provisions. Immigration to the United States may also cause problems. For example, a resident alien (RA) who is the beneficiary of a foreign trust may trigger the interest charge on distributions from a foreign trust, and an RA required to make alimony payments to an NRA may be required to withhold 30% on such payments after becoming a US resident unless the payee resides in a country with income tax protection. The adjusted basis of the NRA s assets does not obtain a step-up could, however, be achieved in a transaction occurring before the NRA moves to the US, which may be tax-free under foreign law but considered taxable under United States law. Income and deductions should be evaluated as to whether acceleration or deferral would be most advantageous, depending on the circumstances. Consideration might also be given to establishing a fiscal year, if possible. In situations where the NRA owns stock in a foreign corporation, directly or indirectly, consideration will need to be given as to whether movement to the US will subject the foreign corporate holdings to the Controlled Foreign Corporation, Foreign Personal Holding Company, Foreign Investment Company and Passive Foreign Investment Company rules. If these provisions could pose problems, then appropriate planning steps will need to be evaluated. Similar arises in the case of interests in foreign partnerships. DEFINITION OF RESIDENT FOR US INCOME TAX PURPOSES The definition of a resident for US income tax purposes is contained in IRC Section 7701(b), enacted in Prior to 1985, the determination of whether an alien was a US resident or non-resident was determined under a facts and circumstances test. In many cases, this is allowed considerable flexibility to tax-payers and their advisors. Starting in 1985, the question of residency is to be determined exclusively under IRC Section 7701(b), which sets forth a number of highly mechanical rules for making the determination both as to residency and as to the precise starting and ending date of residency. An individual is a resident if he or she holds permanent residency in the US (a so-called green card ) at any time during the taxable year. In the absence of permanent residence status, one can be a resident based on the so-called substantial presence test. This treats one as a resident if he or she is present in the US for at least 31 days in a calendar year, 1/3 times the days present during the preceding year, and 1/6 times the days present during the second preceding year equals or exceeds 183 days. The substantial presence test does not apply where a closer connection can be demonstrated between the person and a foreign country. An alien individual treated as an RA under the substantial presence test but present in the US for less than 183 days in the year will not be treated as a resident. This is if the individual establishes that for the current year his tax home is in a foreign country and he has a closer

2 connection with the foreign country than with the US. Also that the individual neither has an application pending for adjustment of status nor takes other steps to apply for lawful permanent residence in the US at any time during the year. The factors to be used in determining whether the individual has a closer connection with the country of his tax home are set fourth in the proposed regulations which require the filing of a closer connection statement by the NRA, and failure to file will result in the NRA being deemed an RA. This provides both opportunities and problems for NRAs, depending on the particular situation. Even though the individual would normally be treated as an NRA for the entire year of arrival in the US, such individual may elect to be treated as an NRA for the entire year of arrival, if certain conditions are met. Most US income tax treaties provide rules for determining residence where an individual would be considered a resident of both countries under the internal law of each (tie-breakers). The Regulations provide that the treaty tie-breaker will prevail and that an individual who is treated as a treaty country resident under a treaty tie-breaker may claim treaty benefits and will be considered an NRA in calculating US income tax liability. (See New Tax Law Definition of US Resident Alien, by Charles P LeBeau, Taxes Magazine, November 1984, Vol. 62. No. 11) DEFINITION OF RESIDENT FOR US ESTATE AND GIFT TAX PURPOSES A different approach to the definition of residence is taken for US transfer tax purposes. The test here is one of domicile. This is, in effect, a common law test. The regulations provide as follows: A person acquire domicile in a place by living there, for even a brief period of time, with no definite present intention of moving therefrom. Residence without the requisite intention to remain indefinitely will not constitute domicile, nor will intention to change domicile effect such a change unless accompanied by actual removal. (Reg (b)(1), (b)) TRANSFER TAX TREATMENT FOR RAs An RA is generally treated in the same manner as a US citizen, so that transfer taxes apply to all gifts and entire gross estate wherever the assets are located. Treaties may grant relief from double taxation. While an RA is generally treated the same as a US citizen, Congress was concerned about the ability of a spouse of an RA, after having received property from the decedent subject to a US marital deduction, to leave the US taxing jurisdiction, so that US estate tax would never be paid on the assets. In order to remedy this problem, it enacted, as a revenue raiser, in the Technical Corrections and Miscellaneous Revenue Act f 1988 (TMRA) a limitation on the marital deduction for assets passing to a non-us citizen spouse. New IRC Section 2056(d)(1) generally provides that there will be no marital deduction of the surviving spouse is not a US citizen. An exception is provided in the case of property passing to a surviving spouse in a qualified domestic trust (QDT). Property passing outside the probate estate is treated as passing in a QDT if transferred to such a trust before the estate tax return is due. (See Alien Taxpayers and Estate and Gift Taxation After The Tax Reform Act of 1984: A Critical Response, by James A. Fellows, Taxes Magazine, November 1984, Vol. 62. No. 11) A QDT, defined in IRC Section 2056A (a) must meet four conditions: 1. The trust instrument must require that all trustees be US citizens or domestic corporations;

3 2. The surviving spouse must be entitled to all the income (as determined under the terms of the governing instrument and applicable local law) from the property in the trust, payable annually or at more frequent intervals; 3. The trust must meet the requirements of Treasury regulations prescribed to ensure collection of the estate tax imposed upon the trust; 4. The executor must make an election with respect to the trust. The election must be made on the estate tax return and, once made, is irrevocable. In order to carry out the objective of assuring that an adequate US transfer tax is paid on the assets in the QDT, an estate tax is imposed upon corpus distributions from the trust made prior to the date of the surviving spouse s death and upon the value of property remaining in a QDT upon the death of the surviving spouse s death. The tax is also imposed upon the trust property if a person other than a US citizen or domestic corporation becomes a trustee of the trust or if the trust ceases to meet the requirements prescribed by the Secretary of the Treasury. The amount of the estate tax is the additional estate tax, which would have been imposed, had the property subject to the tax been included in the decedent spouse s estate. When the decedent spouse s estate tax liability is finally determined, the excess of the tentative tax over the additional estate tax which would have been imposed had the property been included in the decedent estate tax is refundable TRANSFER TAX TREATMENT FOR NRAs In the case of an NRA, only transfers of real or tangible property situated or deemed situated within the United States are subject to gift tax. The federal gift tax rates are the same for NRAs as they are for residents. However, there are some differences regarding deductions and exemptions. NRAs are not eligible for the unified credit.. While NRAs are allowed an annual exclusion of $10, 000 per donee, spouses cannot split gifts. Charitable deductions are allowable provided, basically, that the gifts are to charitable or veterans organisations located in the United States or that the gifts are to be used in the US. The gross estate of an NRA includes all property situated or deemed situated within the United States at death. For example, stock of a domestic corporation is deemed to have a US situs irrespective of the location of the certificate. Conversely, shares of stock issued by a foreign corporation will have a situs without the US irrespective of the location of the certificate. Transfers of property described under IRC Sections are included if the transferred property was situated in the US at the time of transfer or at the time of death. A life insurance policy on the life of an NRA does not have a US situs regardless of where such insurance was purchased. Debt obligations of the United States and its subdivisions and/or US citizens have a US situs. TMRA clarified that bank deposits and certain other debt obligations are considered foreign property for estate tax purposes. NRAs are subject to the same estate tax rates as are citizens and residents after TMRA, but are allowed a unified credit of only $13, 000. TMRA also allowed a marital deduction to the estate of an NRA where property passes to a spouse who is a US citizen. Deductions allowable for a resident decedent s estate under IRC Sections 2053 NRAs based on the ratio of the gross estate situated within the United States to the entire gross estate. It does not matter if the amounts to be deducted were incurred or expended in the United States.

4 ESTATE PLANNING FOR NRAs The essential planning strategy for NRAs who own, or plan to own, assets that could be drawn into the US transfer tax net is to structure arrangements so that an unacceptable and unplanned US transfer tax liability does not occur. In the event that the NRA can take advantage of an estate and gift tax treaty with the United States, or an estate or gift tax credits in the country of death, the danger of double taxation may be reduced. In other situations, careful planning will be in order. 1. Use of Trusts In a typical situation, an NRA may establish a trust in order to hold assets when he, or a member of his family, is contemplating moving to the United States. The trust may be intended to prevent the assets from being subject to US transfer taxation to beneficiaries residing in the United States. Such a trust may or may mot be beneficial to the settlor in his place of domicile. An essential issue in planning for such a trust is the extent to which the individual is willing to give up control. In general, if an NRA transfers certain assets to an irrevocable non-grantor trust before coming to the United States, the trust assets will be moved from his income and estate tax base for US purposes. Unless US situs tangible property is involved, the transfer can generally be made without incurring US gift tax. If the NRA is unwilling to part with control, these benefits may not be possible. For US tax purposes, a foreign trust is a trust whose non-effectively connected income from sources without the United States is not includable in the trust s US gross income. This definition is of little help in the determination of whether a trust is a foreign trust for US income tax purposes. The critical determination is based on a facts and circumstances test which gives weight to such factors as the residence of the trustee, the place of administration, the nationality of the beneficiaries, and the place where the trust is formed. A foreign trust can especially be useful where an NRA is moving to the United States. Since an NRA will become taxable in the United States when he becomes a resident for tax purposes, and since the determination of when this will occur is so difficult to make under income tax conventions and it is so easy to become taxable as a resident under IRC Section 7701(b), incoming NRAs frequently consider creating a non-grantor foreign trust before coming to the US. Income earned by the trust will not then be taxed by the United States, and the value of purely foreign assets, as well as the value inherent in US assets (e.g. interests in US corporations owned by foreign holding company stock of which is held by a trust with no US beneficiaries), will not be subject to US estate tax, should the settlor die while a US person. In the event that funds are needed by the settlor while in the United States, it may be that funds could be paid to the settlor in a manner that will not pose any overall US tax problems, which will depend upon the specific situation. Should the settlor subsequently leave the US and clearly establish residence elsewhere, it may be possible to terminate the trust upon the consent of all interested parties, or trust income could be eliminated in some appropriate manner. Use of a grantor trust by an NRA can be useful where trust beneficiaries (e.g. the grantor s children) are US residents and where the foreign tax rate applicable to the NRA is lower than US rates. Since the grantor will be deemed the owner of the

5 property, the RA beneficiaries will not be subject to tax on the trust s income. But the beneficiaries may be treated as the owners for foreign tax law purposes, so that the grantor is also not subject to tax. The net result could be that there is no effective income tax in this interface situation. 2. Use of Holding Companies Passive investments of NRAs in the United States are often held, directly or indirectly, by a foreign corporation to avoid estate tax on US holdings. While such arrangements may have desirable US transfer tax consequences, as well as income tax consequences (e.g. upon the sale of stock in a US subsidiary), they can pose significant US income tax problems if direct or indirect shareholders of the corporation become US residents and the corporation becomes a Foreign Personal Holding Company. The Foreign Personal Holding Company provisions (FPHC) can be applicable if US citizens or residents own, directly or indirectly, a sufficient amount of the holding company stock, and if the other statutory requirements are satisfied. The FPHC rules apply to any foreign corporation at least 60% (but sometimes 50%) of whose gross income is Foreign Personal Holding Company Income (FPHCI) and more than 50%, by vote or value, of its outstanding stock is owned by five or fewer individuals who are US citizens or residents, except for corporations exempt from tax under IRC Section 501 et. Seq. Or foreign banks not formed or availed or for the purpose of avoiding United States tax on US shareholders. The US shareholders of an FPHC include their pro rata share of undistributed foreign personal holding company income (FPHCI) in gross income on the last day of the taxable year on which they held more than 50%, by vote or value, of the outstanding stock of the foreign corporation. Where the activities of the corporation are more complex than those of a passive investment holding company and where US direct or indirect shareholders (including US trusts or US beneficiaries of foreign trusts) as well as NRAs are involved, reference must be made to a variety of other provisions in the Code. In the case of a foreign corporation held 100% by an NRA s grantor trust (whether or not a domestic trust), the PHC and FPHC rules should have no adverse effect since stock is deemed owned by the NRA. The same is true of non-grantor foreign trusts with no US beneficiaries, attribution rules in the FPHC provisions may lead to indirect stock ownership by United States stockholders which might trigger FPHC treatment. For this reason, it may be good post-mortem planning to consider liquidating holding companies held by an NRA during lifetime but which pass to a foreign trust at the NRA s death, so as to avoid complications of the FPHC provisions, though careful planning will need to be undertaken.

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