How to split ownership on new house purchase

We are both US Citizens and US tax residents. Married for over 20 years in the US. During this time, husband earned all the money from his job, but all money are in “joint” accounts because the American way of thinking about this money is that it is “joint” money earned while we were married. But my understanding is that the Japanese way of thinking about this money might be that it all belongs to the husband.

Now we are going to buy a vacation home in Japan, but still remaining US tax residents. Should we (a) register husband as 100% owner following Japanese thinking, or (b) register husband and wife as 50% owner each, following American thinking.

We might become Japanese tax citizens 5 to 10 years from now, so it might be prudent to split assets now to avoid a large tax bill if husband dies first and passes all assets to wife. (Our total assets exceeds the 160 million yen spousal deduction, and we have no kids or other heirs.) on the other hand, we don’t want to pay a gift tax now if the Japanese tax agency considers that 50% ownership in option b as a gift.

Thanks as always for your knowledgeable advice!

by Small_Factor6931

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