It is complicated and costly enough to purchase a home in Bermuda. Place a multinational marriage or dual citizens into the relationship, and the level of complexity becomes quite extraordinary.Recently, local media have featured a series of articles by Harry Kessaram, an associate in the property department of Conyers Dill & Pearman, that provided an excellent perspective on Bermudian citizens / residents acquiring real estate situated in Bermuda and conveyed according to domestic law and regulations.But what happens if your family members have more than one citizenship, besides being Bermudian? What changes, if anything? The answer, of course, depends on the nature and the country of a second or even third citizenship.The complexity, then, may be derived from many sources: where the real estate is situated, who provides the funding, how the property deed is titled, what type of structure (single family, rental unit, etc.), who acts as guarantor on the mortgage (if borrowing is necessary), whether a trustee will act for the beneficial owner, and how the other country taxing regime views the citizen's liability for tax reporting and filing associated with the structure of the real estate transactions contemplated.To illustrate, in general, how these complexities affect the family in the real world, we will look at the following composite family structure.l Mrs Smith is a US citizen who has almost, but not quite yet, accumulated the requisite time for Bermudian status, has taken steps to apply for Bermuda status.l Mr Smith is a Bermudian whose family arrived (mistakenly on those reefs) on the peaceful isle several hundred years ago.l They have one young child, a son, who is a Bermudian. They have not decided if he should have US citizenship.l They are both employed (fortunately, in this economy). She is only able to work part-time due to child care logistics, while the Mister provides the major share of the household revenue.The Bermudian Ownership Perspective. They have discussed various strategies with their real estate lawyer regarding the titling of this property.1. Should they settle a trust to protect the property ownership for their minor child, and his mother?2. Is an alien licence necessary for Mrs Smith given the close proximity of her Bermuda permanent status?3. If Mrs Smith receives Bermuda status before the conveyance takes place, should she own the property jointly?4. Will they both be guarantors on the mortgage deed?5. Should Mr Smith own the property solely in his name?6. If he owns the property individually, how will the property pass to his non-Bermudian spouse, if he dies prematurely? Does he need a will?7. What will the Primary Family Homestead Certificate do for them if anything?8. Will Mrs Smith's US citizenship impact Bermuda real estate law applicable to their transaction?The United States Perspective. The first question that arises when multinationals (with US citizenship) get together is, what does the United States have to do with a property deal in a foreign country. The answer is, if you are a US citizen, long-term permanent resident (a.k.a green card holder), US resident for income tax purposes, or a Non-resident Alien affiliated with US situs property, or US citizens the US will have plenty to do with it.Where most other countries assert the right to tax their population on the basis of residency, the United States imposes a citizenship based tax regime on its citizens for worldwide income no matter where they reside. The US tax regime has three components: income, gift, and estate tax all of which may come into play during a foreign real estate matter if any of the parties are US persons. Here are a few composite scenarios.1. If Mr Smith settles the Bermuda trust for his son, they will both act as guarantors on the trust mortgage. Mrs Smith may have been named a Protector. She will have significant filing and reporting requirements for US tax law purposes because of her personal guarantee and protector position on a foreign trust. The foreign trustee may also have US reporting requirements.2. If the real property homestead is where the family resides, Mrs Smith, under the US Hire Act effective March of 2010, will be considered to be receiving a deemed benefit (distribution) from the foreign trust. She will be required to remit a monthly rent derived at Fair Market Value in an arms length lease to the trust, or face future tax on the deemed distribution (rent).3. If Mrs Smith becomes a joint title holder, but Mr Smith provided the major source of funds for the acquisition, she may be deemed to have received a large gift from her spouse. This gift from a foreign source is reportable to US Internal Revenue Service.4. As a joint tenant property owner, Mrs Smith will have to structure her estate planning very differently from her foreign spouse due to complex US estate laws regarding estates of US citizens passing to Nonresident alien spouses.5. Mrs Smith's share of any income realised from the rental unit of the property will be subject to tax, filing and reporting with US tax authorities.6. In all events, above certain aggregate balances, Mrs Smith is required to timely report on her Foreign Bank Accounts and Financial Interests, including accounts held jointly with foreign spouses, children and so on.Cross-border caution: multinationals considering any property exchange, transfer, sale, purchase, gift, debt financing, estate legacy wish, or trust regarding real estate or any asset, should seek opinions from internationally experienced financial/legal/tax professionals, preferably in a harmonious collaboration between the professionals (and the countries) involved. Ignoring the tax / legal issues of one country asserting laws over another country in today's international compliance-driven world is exposing your family and the transaction itself to significant tax, legal, and financial risk.The information discussed in this article is general in nature, cannot be interpreted as authoritative advice, or assumed to be a recommended integrated solution for a multinational family. The author makes no representation as to the validity of the information as tax laws, regulations, financial and legal structures can and do change without notice. Any reader identifying with any specific facts in the case above should seek appropriate guidance for their individual situation from qualified finance and legal professionals.Martha Myron, JP CPA CFP(US) TEP, is an international Certified Financial Planner™ practitioner in private wealth management. She specialises in independent fee-only cross-border investment, tax, estate, and strategic retirement planning services for Bermuda residents with United States and multinational connections, and US citizens living and working abroad. She is a Masters in Law candidate in International Tax and Financial Planning and the American Citizens Abroad Country Contact for Bermuda. www.americansabroad.org For more information, contact martha.myron@gmail.com or 296 3528 at Patterson Partners Ltd.