U.S. citizenship-based taxation has many planning repercussions for mixed-nationality families (i.e., where only one spouse is a U.S. citizen), and these are particularly acute when a mixed U.S./non-U.S. couple live and work outside of the U.S. and the family is subject to multiple countries’ tax rules.
How such a couple should proceed depends on a combination of financial and personal factors, including:
– Immigration and tax residence statuses (in the U.S. and elsewhere);
– Where the couple currently lives and where the couple plans to retire;
– The relative incomes of the couple (is one spouse sole breadwinner or are their earnings more evenly divided?);
– The relative family wealth the spouses come from; and
– Personal attitudes toward marital “sharing.”