Passport To Wealth®
Passport To Wealth®
Arielle Tucker
The $60K Estate Tax Trap for Non-US Citizens Holding US Assets
29 minutes Posted May 5, 2026 at 6:00 am.
Meet Hui-chin Chen, CFP®: Wealth for globally mobile families
Accidental Americans: how people become subject to US tax without identifying as American
US citizenship as a second passport: why Asian families acquire it and the tax obligations that follow
Trends in Investment for Non-US citizens: real estate, brokerage account, and alternatives
Tax treaties and the $60,000 US estate tax threshold for non-citizens: what it is and who it catches
Common financial traps for globally mobile families: how claiming a non-US spouse on US taxes triggers foreign reporting requirements
Cultural Differences in Financial Reporting
Best Asian countries for tax planning & immigration
Advice for Globally Mobile Individuals Moving to the US
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Show notes

Hui-chin Chen, CFP®, is the managing partner of Jade & Cowry and has spent her career working with globally mobile families across Asia-Pacific; including her own, as the spouse of a US diplomat who has lived across multiple countries and tax systems. She is one of a small number of practitioners who understands both the technical US tax obligations that reach across borders and the cultural dynamics that make compliance so difficult to achieve.

This episode covers the compliance traps that consistently catch non-US citizens, US-connected individuals, and globally mobile families who never anticipated owing anything to the IRS.

In this episode

  • Accidental Americans and the US tax net - how people become subject to US taxation through birth, the substantial presence test, green card status, or a US spouse, without ever identifying as American
  • Planned citizenship and generational wealth in Asia - how affluent Asian families deliberately acquire US citizenship for the next generation and why, without comprehensive cross-border planning from the beginning, that decision creates compounding reporting obligations for decades
  • The $60,000 US estate tax threshold for non-citizens - why a non-US citizen holding US stocks, real estate, or RSUs from a US employer faces a 40% estate tax above $60,000, how that threshold has never been indexed for inflation, and why almost no Asian countries have estate tax treaties with the US
  • The non-US spouse filing trap - how a US citizen claiming a non-US spouse as a dependent or filing jointly to reduce tax liability can unknowingly pull that spouse's entire foreign financial picture into the US reporting system, creating obligations the non-US spouse never agreed to and may not know exist
  • Joint accounts, family business signatory authority, and FBAR - why common Asian estate planning structures (joint accounts with parents, signatory authority on family businesses) trigger US reporting requirements the account holder never considered
  • Territorial tax regimes across Asia-Pacific - how Singapore, Malaysia, Taiwan, and other territorial systems interact with US citizenship-based taxation, and why holding assets in the US for diversification can create estate tax exposure that offsets the investment benefit entirely
  • The four-to-six month pre-move planning window - why cross-border planning needs to begin months before a move, not after arrival, and why a full financial audit including family account involvement is the mandatory starting point

Resources

  • Connect with Hui-chin on LinkedIn
  • Are you a qualified professional serving US expats in France or Europe? Apply to passporttowealth.com/join
  • Subscribe to the Passport to Wealth newsletter: passporttowealth.com/contact
  • Find a vetted cross-border advisor: passporttowealth.com/directory

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