别自己吓唬自己,

For green card spouse, annual gift exclusion is $160,000 from citizen spouse.  This means gift under this amount will not have any tax consequences.  (Gift between citizen spouses are unlimited).  

For amount over $160,000, the citizen spouse just need to report the amount $X on his tax return and deduct from the citizen's estate tax exemption ($11 million).

And when citizen spouse die, the green card spouse would have the estate tax exemption of ($11 milllion - $X).   (inheritance between citizen spouse are unlimited).  

So to recap:  annual gift exclusion of $160,000 means gift under $160,000 from citizen spouse to non-citizen spouse is completely tax free.  Any amount above $160,000 will be deducted from estate tax exemption.  So that green card spouse only pay tax when the life time gift + estate is > $11 million. 

 

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