ARAI CPA / Families with ties to the U.S. and Japan

For U.S.–Japan Families

A succession plan that is right in Japan can produce a different answer in the United States.

A successor with U.S. citizenship, a father who kept his green card, a subsidiary or property in the U.S., or you yourself living there. Any one of these puts an estate, a gift or a business succession inside two tax systems at once. A Japanese CPA and tax accountant who began in U.S. tax practice puts both systems on the table and designs the order of steps that puts the least strain on the family and the business.

Book a free first consultation See typical situations

Situations

Situations we see

Cross-border problems tend to appear as a decision that is correct in one country and a problem in the other.

The successor to the family company is a U.S. citizen

Transferring the shares in one gift under Japan's business succession relief is the right choice in Japan. If the successor is a U.S. citizen, the share, timing and value of the gift matter for U.S. gift tax, the company's profits fall under GILTI, and the company's bank accounts fall under FBAR.

The issueWhich stake, to whom and when changes the U.S. valuation and the exemption used. Never copy the Japanese tax-ruling value into a U.S. return. The U.S. records (E&P, §962 elections) must be assembled the year before the gift.

Father lives in Japan and still holds a green card

Give it up or keep it? Giving it up raises the expatriation tax (§877A) and the §2801 tax on later gifts and bequests. Keeping it means a U.S. return and account reports every year.

The issueThe order of retirement pay and surrendering the card changes the tax rate dramatically; keeping the card is often the cheaper answer. Long stays in the U.S. can also trigger Japan's exit tax.

Selling or inheriting U.S. real estate while resident in Japan

Alongside the U.S. filings, a Japanese resident reports worldwide income and worldwide assets in Japan. Where a trust or will was drafted under U.S. law, its interaction with Japanese inheritance tax has to be checked.

The issueCredits under the U.S.–Japan estate tax treaty, the timing mismatch in foreign tax credits, and how Japan taxes trust beneficiaries. We work with your U.S. attorney and CPA and handle the Japanese filings and advice.

A U.S. citizen working in Japan: Japanese accounts, RSUs and NISA

Japanese salary, RSUs, gains in a NISA account, a Japanese pension. U.S. citizens and green card holders file in the U.S. wherever they live; NISA gains that Japan exempts are taxable in the U.S. and are treated differently again in the foreign tax credit calculation.

The issueJapanese withholding against the U.S. calendar year, Form 1116 categories, account classification for Form 8938 and FBAR, and whether a child is in fact a U.S. citizen. Past omissions can often be cured under the Streamlined procedures.

The problem is rarely non-filing. It is filing by people who cannot see the whole picture: a Japanese tax accountant and a U.S. CPA each doing their part for the same family without knowing the other exists.From our work on U.S.–Japan successions

What we do

We act as the Japanese side, and divide the work with your U.S. CPA and attorney. We deal first with the points where a Japanese decision or document decides the U.S. outcome.

Estate, gift and succession under both systems

Japanese succession relief alongside U.S. gift and estate tax, stake and timing design, the estate tax treaty, obtaining the valuation and handing it to the U.S. side.

Expatriation and the green card decision

Whether and in what order to surrender (retirement pay, resignation, dividends), §877A and §2801 estimates, sequencing with Japan's exit tax.

CFC, GILTI and information reporting

Form 5471, Form 8992, HTE and §962 elections, FBAR and Form 8938 account inventories, and a routine that gets the Japanese company's records to the U.S. return every year.

Japanese filings for U.S. citizens and residents

Japanese income, inheritance and gift tax returns aligned with the U.S. filings; foreign tax credit timing; overseas asset and asset-and-liability reports.

Japanese tax for Americans and Japanese living in the U.S.

Non-resident filings on Japanese property, shares and inheritances, and tax design for a return to Japan.

Tax simulation

Scenario models with gift timing, stake, valuation and both countries' rates as variables: what changes, by how much, and when, in tables and charts.

FAQ

Common questions

I live in the United States. Can you act for me?

Yes. Meetings are online and scheduled around the time difference. We handle the Japanese side and coordinate with a CPA in the U.S.

Will you prepare my U.S. returns as well?

U.S. returns are prepared with a U.S. CPA. We handle the Japanese decisions and documents and check that the two sides agree. If you already have a U.S. CPA, we work with them directly.

Some of my family speak only English.

Everything can be in English: meetings, correspondence, documents. Family members are welcome to join.

I may have missed past U.S. filings.

Non-willful omissions can often be cured under the Streamlined procedures with three years of returns and six years of FBARs, without penalty for those living abroad. We start by hearing the facts.

Lecture, October 2026, YUI Wealth Tax & Succession Master Series 2026Estate Practice with Non-resident Heirs and Foreign Assets: Share Valuation and Post-gift Tax Risk
YUI Report vol. 8The Deep Mismatch in U.S.–Japan Business Succession

Contact

The first hour
is free.

We organize your situation, identify the issues, and tell you plainly whether we can help. We reply within two business days.

Emailinfo@araicpas.com
Tokyo5-5-17-303 Kugayama, Suginami-ku, Tokyo 168-0082, Japan
KoriyamaCorpo Bldg. 301, 1-5-1 Tsurumidan, Koriyama, Fukushima 963-8861, Japan
MeetingsIn person / Online (Zoom, Teams), scheduled around U.S. time zones

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