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My father was a non-resident alien who owned U.S. real estate. Do we need to file Form 706-NA?
My father recently passed away. He was a citizen of Mexico and never lived in the U.S., but he owned a vacation condo in Texas worth about $400,000. He also had a U.S. brokerage account with about $150,000 in U.S. stocks. I'm the sole heir. Do we need to file a U.S. estate tax return? I've heard that non-residents only get a $60,000 exemption which seems shockingly low compared to the $12 million exemption for U.S. citizens.
Related Questions
What is GILTI and how does it affect U.S. shareholders of foreign corporations?
I keep hearing about GILTI in the context of international tax reform. I'm a U.S. person who owns a foreign company, and someone told me I might owe tax on income my foreign company earns even if I never take a dividend. That sounds crazy to me. Can someone explain what GILTI actually is, how it works at a high level, and who it applies to? I want to understand the basics before I talk to my CPA.
I'm a foreign person owning a U.S. LLC — do I need to worry about GILTI?
I'm a non-U.S. resident who owns a single-member LLC in the United States. My LLC provides consulting services to clients in the U.S. and abroad. A friend told me about GILTI and said I should check if it applies to me. But everything I read says GILTI is for U.S. shareholders of foreign corporations. I'm a foreign person owning a U.S. entity — isn't that the opposite? Do I need to worry about GILTI at all, or is this a non-issue for someone in my situation?
How do you calculate GILTI? What are tested income, QBAI, and net DTIR?
I understand GILTI at a high level but I'm struggling with the actual calculation. My CPA mentioned terms like 'tested income,' 'QBAI,' and 'net deemed tangible income return' and I got lost. I own a U.S. holding company that has two CFCs — one is profitable and the other is running at a loss. Can someone walk me through the mechanics of how GILTI is actually computed? And does the loss from one CFC offset the income from the other?
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