IRS Cryptocurrency Update:  Taxing Those”Hard Forks” and “Air Drops”

Cryptocurrency (such as Bitcoin) is a type of virtual currency. It is an emerging area, and as such, comes with an enormous amount of uncertainty when it comes to the US tax treatment of transactions involving its use. On October 9, the Internal Revenue Service (IRS) issued Revenue Ruling 2019-24 providing much awaited guidance about … Continue reading IRS Cryptocurrency Update:  Taxing Those”Hard Forks” and “Air Drops”

NEWS FLASH! 2019 Tax Returns: Get Ready for Questions About Your Virtual Currency Holdings

It’s no secret, the IRS is very serious with its crackdown on virtual currency. In July, the agency started sending letters to taxpayers who may not have been in compliance with regard to their use of virtual currency.  Things are heating up and there’s more to come. The early release draft of the IRS Form … Continue reading NEWS FLASH! 2019 Tax Returns: Get Ready for Questions About Your Virtual Currency Holdings

Is the IRS Trying to Find You?

Moving is always a stressful event and it is easy for certain things to be overlooked. One item on your moving checklist that is critical to remember: properly notifying the Internal Revenue Service (IRS) of your change of address.  Today's post tells you how to do it right and the terrible things that can happen … Continue reading Is the IRS Trying to Find You?

“Purported Gifts” from a Foreign Corporation or Partnership- Exceptions & Application of PFIC Rules

My earlier blog post explained the unpleasant tax effects that occur when a US person receives a "gift" from a foreign corporation or a foreign partnership. Yes, bad things happen.  The general tax treatment for gifts will not apply.  Usually, a gift is not treated as taxable income to the recipient. However, when the gift … Continue reading “Purported Gifts” from a Foreign Corporation or Partnership- Exceptions & Application of PFIC Rules

OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)

Here in the Middle East where I have been practicing for almost two decades, I have seen that it is very common for families to create offshore structures in various countries (outside the USA) to hold a large portion of the family wealth.  The underlying reasons for maintaining these structures outside of the family’s home … Continue reading OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)

FALSE! Failure to File Form 8854 Means Continued Liability for US Tax on Worldwide Income

For today's post, let me start with the Conclusion! If you expatriate after June 16, 2008 and you fail to file Internal Revenue Service (IRS) Form 8854 (Initial and Annual Expatriation Statement), you DO NOT have continued US income tax liability on your worldwide income.  It's that simple. You may have read or heard otherwise … Continue reading FALSE! Failure to File Form 8854 Means Continued Liability for US Tax on Worldwide Income

D is for “Domicile”, Don’t Disregard!

Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one  is a US person and they are impacted by application of a foreign country’s community property laws.  You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!

Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!

The Internal Revenue Service (IRS) announced today new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished 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, or any penalties or interest!  It sounds … Continue reading Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!

US Tax Filings by Fiduciary of Foreign Trust

I have written various blog posts covering foreign (i.e., non-US) trusts. Many of them concern US tax filing and reporting requirements with regard to such trusts.   My initial post provided a general overview of the troublesome US tax issues surrounding foreign trusts, and my blog post here navigates  the tricky waters in determining if a … Continue reading US Tax Filings by Fiduciary of Foreign Trust

Passport Non-Issuance/Revocation: A Welcome Reprieve for Some Tax Debtors

On August 8th, the Internal Revenue Service (IRS) reminded taxpayers with “seriously delinquent tax debt” that they can lose their US passports. I will provide more detail on this below, but first, the “good news”.  It was announced on August 14, 2019 that Charles Rettig, the IRS Commissioner, has granted a reprieve for some tax debtors … Continue reading Passport Non-Issuance/Revocation: A Welcome Reprieve for Some Tax Debtors