Author: ustaxinternational

US Tax specialist based in Dubai since 2001. I am a member of the NYS Bar since 1984 and am admitted to the US Tax Court. My areas of specialty include US/international tax planning for US persons or foreign persons with any US connections; expatriation matters, regaining US tax compliance, voluntary disclosures, offshore accounts and assets, FATCA. Forbes Top 100 Tax Twitter Account 2017-2019.

SECURE Act – Changes to Retirement Plan and IRA Rules – No More Big “Stretch”, Work Longer, Contribute More 

Right before Saint Nicholas’ Christmas visit, President Trump signed the "Further Consolidated Appropriations Act, 2020" to provide necessary funding to keep the federal government running through September 30, 2020. Included in the Appropriations Act was an additional piece of legislation commonly referred to as the “SECURE Act” (the full title is “Setting Every Community Up … Continue reading SECURE Act – Changes to Retirement Plan and IRA Rules – No More Big “Stretch”, Work Longer, Contribute More  →

Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief

NEWS FLASH! The Internal Revenue Service (IRS) announced today that there are limited circumstances in which it may be appropriate to provide relief from "double taxation" resulting from application of the repatriation tax under Internal Revenue Code Section 965, as amended by the Tax Cuts and Jobs Act (TCJA). The IRS has determined that in … Continue reading Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief →

IRS: The Grinch Who Stole Christmas

Christmas was on our doorstep not too long ago and was marked by a time of giving and rejoicing. In the employment context, overseas employers with American staff may have been more inclined to be generous in gift-giving, as many of its US employees were away from their Stateside family over the holiday period.  The … Continue reading IRS: The Grinch Who Stole Christmas →

Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners

With Christmas having recently been on our doorstep, now is the time to review what tax consequences are in store for gift givers and their lucky recipients.  US tax filings might be required of a US individual who receives a gift (whether in cash or property of some kind - you know, a 5 carat … Continue reading Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners →

ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses.  In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture.  This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return! →

IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?

In September 2019, the Internal Revenue Service (IRS) announced new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished (or are relinquishing) their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed; nor will … Continue reading IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders? →

Dangerous Liaisons: Foreign Assets and the US Nominee

We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by financial institutions that were the subject of non-prosecution agreements, as well as examining treasure troves of financial information from various leaks (think “Panama Papers”) looking not only for tax dollars, interest and penalties but … Continue reading Dangerous Liaisons: Foreign Assets and the US Nominee →

President Trump – Expatriating?

Well, if my dream last night has anything to do with reality, the world is in for a big shakeup.  In my dream, President Trump came to me for US tax advice on expatriation - that is giving up one's US citizenship (or, green card in the case of long term residents). What a bizarre … Continue reading President Trump – Expatriating? →

Cryptocurrency – Criminal Investigations have Commenced!

First, a special thank you to Steve Phillips, a tax & business lawyer in Texas, who alerted me to this recent development. According to an Internal Revenue Service (IRS) special agent, Mr. Chris Hueston, the IRS has now officially begun investigations into tax evasion and other crimes tied to cryptocurrency. The announcement made on November … Continue reading Cryptocurrency – Criminal Investigations have Commenced! →

US Beneficiary of Foreign Trust: Understanding US Tax Filings

I have written a series of blog posts about foreign (i.e., non-US) trusts and the US tax issues associated with them including the US tax filing and reporting requirements for each of the different players in the foreign trust scenario (creator or "grantor"/"settlor" of the trust), the trustee; and today, the US beneficiary. One of … Continue reading US Beneficiary of Foreign Trust: Understanding US Tax Filings →