Jack Holowczak — personal property appraiser, Toronto

Appraisals for U.S. Citizens & Green-Card Holders Abroad

USPAP-Compliant · Personal Property · Remote, Worldwide

U.S. citizens and green-card holders remain within the U.S. federal tax system wherever in the world they live. When a collection — handbags, watches, jewelry, fine art — meets a U.S. filing threshold, the rules governing who may value it travel with the filer: London, Dubai, Singapore, Hong Kong, Sydney, or anywhere else.

Income-tax residence and estate/gift-tax domicile are different tests. For estate and gift tax, holding a green card is not conclusive; counsel determines which filing regime applies. This practice provides the personal-property valuation required for the selected filing.

Jack Holowczak is a qualified appraiser under 26 CFR §1.170A-17, preparing USPAP-compliant appraisal reports for U.S. tax purposes on a fully remote, documentation-driven basis. Time zones are not a constraint; engagements are conducted asynchronously and in writing. Non-U.S. persons holding property located in the United States are addressed separately — see Form 706-NA appraisals. Canadians relocating to the United States may also need CRA departure-tax appraisals.

Common engagements include appraising a handbag, watch, or jewellery collection for a U.S. tax filing while living overseas.

Services

Charitable Contributions — Form 8283. Noncash charitable deductions above $5,000 generally require a qualified appraisal by a qualified appraiser, reported on Form 8283. Timing rules apply: the appraisal must be made no earlier than 60 days before the date of contribution and no later than the due date of the return on which the deduction is first claimed.
Estate & Gift — Forms 706 and 709. Estates of U.S. citizens and residents are reported on worldwide assets; tangible personal property is valued at fair market value as of the date of death, or the alternate valuation date where elected, for Form 706. Lifetime gifts above the annual exclusion are reported at fair market value on Form 709. Appraisal reports state the standard of value, effective date, scope of work, and assumptions. Form 706 appraisals are provided under oath where 26 CFR §20.2031-6(b) requires it.
Fully Remote Methodology. Engagements are documentation-driven: photographs, receipts, provenance records, and prior documentation, with comparable-sales analysis drawn from primary auction records (Heritage Auctions, Sotheby's, Christie's, Bonhams, Phillips, Heffel, and Cowley Abbott) and licensed databases. Reports comply with USPAP Standards 7 and 8.
Fees. Engagements are quoted by engagement letter based on scope of work, time, and complexity. Fees are never contingent on appraised value. Where a reported value is disputed, see the expert witness practice.

What to Send

How the Engagement Runs

  1. Inquiry and conflict check.
  2. Engagement letter stating intended use and users, standard of value, and effective date.
  3. Documentation exchanged electronically.
  4. Examination of the record and a USPAP Standards 7 and 8 report, in the currency the filing requires.
  5. Delivery to you and your advisor; where applicable, the appraiser's declaration on the relevant form is completed.

Frequently Asked Questions

Can a U.S. expat engage an appraiser located outside the United States?

The regulations define a qualified appraiser by education, experience, and adherence to professional appraisal standards — 26 CFR §1.170A-17 — not by the appraiser's location or the client's. Reports are prepared in accordance with USPAP and the applicable substantiation requirements.

Do you need to physically inspect the items?

Engagements are documentation-driven and conducted remotely; the scope of work and any assumptions are disclosed in the report in accordance with USPAP. Where counsel or a filing position requires physical examination, that is addressed by written agreement before the engagement begins.

My items are located outside the U.S. Does that matter?

Fair market value is developed from the relevant market for the property, and values for U.S. filings are reported in U.S. dollars. The physical location of the items does not prevent a remote, documentation-driven appraisal.

Is this tax advice?

No. This page describes appraisal services only. Filing positions belong to you and your tax advisor or counsel; reports are prepared to support the values they report, and engagements routinely run alongside existing advisors.

How much does a tax appraisal cost?

Engagements are quoted by engagement letter based on scope of work, time, and complexity — the number of items, the state of documentation, and the intended use of the report. Fees are never contingent on appraised value.

I inherited jewelry or art from a foreign relative. Does Form 3520 need a valuation?

For gifts or bequests from a nonresident alien individual or foreign estate, Form 3520 reporting generally applies when the applicable annual aggregate exceeds $100,000. Related-party aggregation rules apply; purported gifts from foreign corporations or partnerships have a different threshold. Part IV of Form 3520 asks for a description and the fair market value of the gifts or bequests reported; an appraisal can document that value for jewelry, art or other personal property. Your tax advisor determines the filing requirement and how any inherited or gifted property's tax basis should be established.

Can you complete the appraiser declaration on Form 8283 if I live abroad?

Yes. The appraiser's declaration on Form 8283 is completed and signed by the appraiser as part of the engagement; neither the client's location nor the appraiser's is a barrier. Signed forms and reports are delivered electronically.

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