Section 965 Transition Tax – Enforcement & Audits Begin Next Month

By now most of my readers will have some familiarity with  Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017.  My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month

2020 Tax Returns & Latest Crypto Developments – In the Crosshairs

The Internal Revenue Service (IRS) just recently released the 2020 draft Form 1040.  In your face right on page one, on a separately colored block: “At any time during 2020, did you receive, sell, send, exchange or otherwise acquire any financial interest in any virtual currency?”  This question first appeared for the 2019 tax return, but … Continue reading 2020 Tax Returns & Latest Crypto Developments – In the Crosshairs

Rich Americans…. Time to Wake Up!

Rich Americans (or foreigners with US assets), it's time to wake up and smell the coffee!  Why?  I am seeing more and more individuals with influence pushing for a change in the US tax laws so that wealth inequality becomes a thing of the past.  Whether you agree with this position is not the point … Continue reading Rich Americans…. Time to Wake Up!

Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations – is it limited to a $100,000 cap or can the penalty, if greater, be assessed at 50% of the value of the unreported account? More detailed background on this issue is available at my … Continue reading Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

Divorcing the United States: Two Methods – Renunciation and Commission of an Expatriating Act with “Intent”

This post is a sequel to "Expatriation – Giving up US Citizenship – Will I be Banned from Re-entering the USA?" my earlier blog post analyzing the so-called "Reed Amendment".  As discussed in that post, since the statutory language of the Reed Amendment applies only to those who “officially renounce” United States citizenship it may be … Continue reading Divorcing the United States: Two Methods – Renunciation and Commission of an Expatriating Act with “Intent”

Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?

Well, the numbers of individuals renouncing US citizenship is apparently reaching epic proportions.  It has been reported that 5,816 Americans gave up their citizenship in the first six months of 2020 and that this represents a 1,210% increase from the prior six months ending December 2019, when only 444 cases were recorded.  Most clients I … Continue reading Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?

Clash of the Titans:  Can we Harmonize US Tax and Shariah Laws?

Recently, I was asked by Islamic Finance News, a leading provider of news in the Islamic financial world, to write an article addressing a largely unexplored topic.  What is it? Why is it essentially uncharted and not discussed?  The topic involves the unique impact on financial and other transactions when US tax and Shariah laws … Continue reading Clash of the Titans:  Can we Harmonize US Tax and Shariah Laws?

Lifting the Veil on US Shell Companies – Third Attempt to Force Beneficial Ownership Registers

Play it again (Uncle) Sam! Two US senators are trying yet again to enact a law mandating creation of a national database of beneficial owners of US businesses.  So far we have seen two unsuccessful attempts by lawmakers for mandatory beneficial ownership registers in the USA. The latest borrows heavily from the two bills that have … Continue reading Lifting the Veil on US Shell Companies – Third Attempt to Force Beneficial Ownership Registers

MAJOR FBAR WIN for the Taxpayer! Penalty is Per FBAR Form, Not Per Account

Since the early 1970’s the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them.  Many individuals now know about the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts). It comes as a surprise to many, however, to learn that the … Continue reading MAJOR FBAR WIN for the Taxpayer! Penalty is Per FBAR Form, Not Per Account

FBAR “Willfulness” – Fifty Shades of Gray

It’s been awhile since I have blogged about our friend, Mr. FBAR.  For those of you who are not familiar with his nickname, you may know him by his more formal moniker “Report of Foreign Bank and Financial Accounts” (FinCEN Form 114).  He springs from Title 31 of the Bank Secrecy Act (not the Internal … Continue reading FBAR “Willfulness” – Fifty Shades of Gray