Droit Fiscal Américain
Gift Tax Implications for U.S. Citizen Spouses Giving to Non-U.S. Citizen Spouses
Published on: 26/10/2025
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.
US Tax
𝐄𝐬𝐭𝐚𝐭𝐞 𝐨𝐟 𝐑𝐨𝐰𝐥𝐚𝐧𝐝 𝐯. 𝐂𝐨𝐦𝐦𝐢𝐬𝐬𝐢𝐨𝐧𝐞𝐫, 𝐓.𝐂. 𝐌𝐞𝐦𝐨 𝟐𝟎𝟐𝟓-𝟕𝟔
Published on: 26/10/2025
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.
US Tax
SEC v. Jarkesy – Potential Ripple Effects in U.S. Tax Enforcement
Published on: 13/10/2025
The 2024 SEC v. Jarkesy ruling grants a jury trial right for civil fraud penalties, reshaping U.S. tax enforcement. It may shift IRS strategies, increase jury trials, and add complexity to tax litigation. THEVOZ & Partners guides clients through these changes.
US TaxLitigation
