Arvelle was born and raised in Wales, England. She came to the United States between the ages
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Question:
Arvelle married Henry who is Taiwanese. Arvelle and Henry married in California where they lived briefly.
The couple moved back to Foreign Country X for 15 years while maintaining homes in the U.K., California, Taiwan, and Foreign Country X. They have two daughters, Rosie and Lily. Rosie and Lily are U.S. citizens.
Henry is expected to inherit large wealth. His mother and father live in Taiwan and want to establish an effective estate plan to pass over Henry's inheritance.
In year 16 of their marriage, Henry and Arvelle moved to the U.K. where Henry started a bio-tech start-up. It is unclear where the funds came from that funded the start-up. The U.K. start-up is in his name. In year 20, Arvelle and Henry moved back to Foreign Country X. The start-up is worth $300 million.
Rosie is going to study in the U.S.
Arvelle's father wants to set up an inheritance plan for her. He wants to get the assets out of the U.K. harsh inheritance tax.
Here is a list of Arvelle's and Henry's assets:
U.S. Assets
Arvelle has several bank accounts in her name in California. These were accounts that were opened when she studied in the U.S. Today the combined value of the accounts total $2.5 million.
Henry and Arvelle have joint savings accounts in one of the U.S. banks. Henry recently transferred $2 million for Rosie's study in the U.S. He plans to fund her education and purchase a home in Washington, D.C. where Rosie will reside. The home will likely be in his name for the time being.
Arvelle owns a home in Long Beach, CA, worth about $1.5 million. Her father bought this home when Arvelle studied in the U.S. The cost basis is estimate at $150,000.
Arvelle and Henry own a home in Beverly Hills.
Foreign Country X (Mexico)
They own a home in Foreign Country X worth $20 million.
The two factories are under Arvelle's father's name and he wants to give those factories to her now. They received an offer to purchase the factories.
Henry owns a foreign company that has a large investment portfolio.
Arvelle and Henry have a stock account in Foreign Country X.
Taiwan
Henry and Arvelle own two homes in Taipei. They occupy one and rent out the other. The value of the homes totals $10 million.
Henry's mother gifted him a ranch in Taipei.
U.K.
Arvelle and Henry own a property in Wales worth $2 million.
The shares of the U.K. start up are worth over $300 million
Arvelle's share in her father's company are worth $200 million.
What assets are Arvelle's for U.S. income tax purposes? What assets are Arvelle's for U.S. estate and gift tax purposes?
Keep in mind whether the assets are community or separate property assets? Consider IRS Sec 879...
What assets are Henry's for U.S. income tax purposes? What assets are Henry's for U.S. estate and gift tax purposes?
Same question: Are the assets community or separate property assets? Remember the case of Charania
Related Book For
Business and Administrative Communication
ISBN: 978-0073403182
10th edition
Authors: Kitty o. locker, Donna s. kienzler
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