Thank you all for your input and thoughts.
It seems I'm not worrying for nothing (or being concerned for nothing![:P]( "Razz")
), and that I'll have to keep staying informed and planning. And also I understand that things could change due to laws or asset values (an year of hyperinflation already does the trick...).
I want to find a strategy that can work and I can live with (i.e. not losing 40-70% of the family's net worth).
Here are some actionable scenarios, and I'd appreciate your feedback. (Again, I'm only looking for legal and legitimate options, and if I write an option that doesn't fit in this category I don't recommend anyone following it!)
1. Entire family keep green card forever and live in US "forever". No exit tax. No inheritance tax up to 13/6M.
2. Family leaves US before January 2033. No exit tax. No inheritance tax up to 13/6M, or more if no US assets.
3. Spouse and kids become US citizens. I gift everything to my spouse and my pension manages to stay <2M. We leave US but I'm not covered expat. No exit tax. No inheritance tax up to 13/6M.
4. Same as 3, but my pensions value is >2M. We leave and I'm a covered expat. Exit tax, but with gifting the tax amount can be minimized. 30% tax on future pension. I live my life gifting to my spouse my salary every year to own no assets. If I die before my spouse, no inheritance tax and eventually the children will receive the assets tax-free up to 13/6M.
4b. Same as 4, but my spouse dies first (sorry for being morbid). We set it up so that the children receive most of it, and I live with my pension and whatever they gift me every year (<180k/year, inflation indexed). The children receive the assets tax-free up to 13/6M.
5. Spouse and kids become US citizens. My pension becomes >2M. I gift most assets and leave and I'm a covered expat. Exit tax, but with gifting the tax amount can be minimized. 30% tax on future pension. Shortly after, spouse and children also renounce and become expats. We move all assets to non-US. Eventually the children will receive the assets tax-free. But to return to the US the children need to apply for a visa.
(Whenever I wrote tax-free I neglected non-US taxes)
And now some gray-area solutions.
6. To avoid becoming a covered expat at all costs, since the 2M threshold is on the net worth (assets - liabilities), could one buy a property asking for a mortgage, and gift the house immediately after? So if one has 3M assets, could one buy a 2M house with 1.6M mortgage, gift the house, and remain with a net worth of 3-1.6=1.4M? (I understand the mortgage remains a real liability and this scenario requires high trust in the family)
7. In scenario 4/4b (covered expat), since a 40% tax applies to gifts made from covered expats to US persons, could one transfer all assets to non-US, gift them all to a non-US person (a trusted relative for example), and then could the relative gift them to one of the children? I believe these steps would be tax-free, but I'm not sure this is considered acceptable.
Can you think of other ideas?
Thank you in advance for your feedback!
It seems I'm not worrying for nothing (or being concerned for nothing
), and that I'll have to keep staying informed and planning. And also I understand that things could change due to laws or asset values (an year of hyperinflation already does the trick...).I want to find a strategy that can work and I can live with (i.e. not losing 40-70% of the family's net worth).
Here are some actionable scenarios, and I'd appreciate your feedback. (Again, I'm only looking for legal and legitimate options, and if I write an option that doesn't fit in this category I don't recommend anyone following it!)
1. Entire family keep green card forever and live in US "forever". No exit tax. No inheritance tax up to 13/6M.
2. Family leaves US before January 2033. No exit tax. No inheritance tax up to 13/6M, or more if no US assets.
3. Spouse and kids become US citizens. I gift everything to my spouse and my pension manages to stay <2M. We leave US but I'm not covered expat. No exit tax. No inheritance tax up to 13/6M.
4. Same as 3, but my pensions value is >2M. We leave and I'm a covered expat. Exit tax, but with gifting the tax amount can be minimized. 30% tax on future pension. I live my life gifting to my spouse my salary every year to own no assets. If I die before my spouse, no inheritance tax and eventually the children will receive the assets tax-free up to 13/6M.
4b. Same as 4, but my spouse dies first (sorry for being morbid). We set it up so that the children receive most of it, and I live with my pension and whatever they gift me every year (<180k/year, inflation indexed). The children receive the assets tax-free up to 13/6M.
5. Spouse and kids become US citizens. My pension becomes >2M. I gift most assets and leave and I'm a covered expat. Exit tax, but with gifting the tax amount can be minimized. 30% tax on future pension. Shortly after, spouse and children also renounce and become expats. We move all assets to non-US. Eventually the children will receive the assets tax-free. But to return to the US the children need to apply for a visa.
(Whenever I wrote tax-free I neglected non-US taxes)
And now some gray-area solutions.
6. To avoid becoming a covered expat at all costs, since the 2M threshold is on the net worth (assets - liabilities), could one buy a property asking for a mortgage, and gift the house immediately after? So if one has 3M assets, could one buy a 2M house with 1.6M mortgage, gift the house, and remain with a net worth of 3-1.6=1.4M? (I understand the mortgage remains a real liability and this scenario requires high trust in the family)
7. In scenario 4/4b (covered expat), since a 40% tax applies to gifts made from covered expats to US persons, could one transfer all assets to non-US, gift them all to a non-US person (a trusted relative for example), and then could the relative gift them to one of the children? I believe these steps would be tax-free, but I'm not sure this is considered acceptable.
Can you think of other ideas?
Thank you in advance for your feedback!
Statistics: Posted by roller_coaster — Sun Dec 07, 2025 2:25 am — Replies 8 — Views 990