Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Taxpayers have often struggled with shifting tax filing deadlines and complex IRS penalty calculations. But if some of those filing deadlines were legally postponed by an act of Congress, certain penalties and refund interest may have been incorrectly calculated by the IRS, entitling impacted taxpayers to relief. A recent federal court case may offer some … Continue reading Kwong Case: IRS May Owe You Money, Cut Penalties
In a stark reminder of the complexities and pitfalls of renouncing U.S. citizenship, a federal grand jury in the Western District of Texas recently indicted Justin Ryan Schmidt on multiple tax-related charges. Mr. Schmidt, a Cayman Islands national, is a former U.S. citizen and cryptocurrency hedge fund manager. He became a naturalized British citizen in … Continue reading BREAKING! Ex-U.S. Crypto Mogul Indicted: The High Cost of Botched Expatriation
For Americans considering giving up U.S. citizenship or abandoning a green card, understanding how Social Security benefits are treated abroad is essential. Many assume that once they qualify for Social Security based on U.S. work history, payments will follow them anywhere on the globe. For U.S. citizens, this is basically correct. For non-U.S. citizens, including … Continue reading Collecting Social Security Abroad: Understanding SSA Country List 4
Right before the U.S. tax filing season officially opened on January 26, the Internal Revenue Service announced significant leadership changes that have drawn cautious scrutiny from tax professionals. Practitioners with the high-net-worth clients and those who assist Americans living abroad are paying close attention. While IRS leadership transitions regularly occur, the timing and substance of … Continue reading IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?
Most people assume that once they have qualified for Social Security based on their U.S. earnings, their monthly benefit will follow them anywhere in the world for life. This is true for U.S. citizens. But for non-U.S. citizens, including former U.S. citizens and former green-card holders, the rules are very different. These individuals are classified … Continue reading Some Foreigners Can’t Receive U.S. Social Security Abroad: Understanding SSA Country List 2
The Internal Revenue Service has released the final version of Form 708, titled “United States Return of Tax for Gifts and Bequests Received from Covered Expatriates,” (revision dated December 2025) along with detailed draft instructions (revision dated December 2025). As of today’s publication, the accompanying instructions remain in draft form available only as a draft … Continue reading IRS Drops Form 708: 40% Tax, Gifts & Bequests, “Covered Expatriates”
For many Americans, relinquishing U.S. citizenship or green-card status offers an exit from U.S. tax and filing obligations. I have previously written about the harsh tax consequences on Social Security for those who give up U.S. status. Many individuals who are contemplating giving up their U.S. citizenship or relinquishing a green card focus on the possibility of having to … Continue reading Receiving U.S. Social Security Abroad: Understand SSA Country List 1
I have previously written how changes to U.S. citizenship and expatriation rules often produce consequences far beyond what legislators appear to anticipate. Whether in the tax arena or in the administration of federal benefits, citizenship status functions as a foundational legal concept, not a standalone policy. Senator Moreno’s proposed “Exclusive Citizenship Act” underscores this point. … Continue reading Exclusive Citizenship Act: Unintended Consequences Continue To Emerge
One email from a tribal member sparked today’s article. A Native American reader of my recent Forbes piece on Senator Bernie Moreno’s Exclusive Citizenship Act of 2025 wrote in with a simple, powerful question: “How would this affect us?” In fewer than 10 words, that message prompted me to dig much deeper. What follows is … Continue reading Moreno’s Fast-Track Citizenship Bill: Tax & Social Security Bombs, Diplomatic Chaos & More
The United States along with over 70 other countries has adhered to the Joint Statement on the OECD’s Crypto-Asset Reporting Framework, “CARF”. CARF is the digital-asset counterpart to the Common Reporting Standard “CRS” that has exchanged bank and securities account data among signatory countries (now well over 100 countries). The United States has formally indicated … Continue reading Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF
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