Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
If you or your clients are really (really) wealthy (more than $100 million in annual income or more than $1 billion in assets) and thinking about expatriation (relinquishing US citizenship or a green card as a long-term resident), the time is now. Even if not super wealthy, the newly proposed Billionaires Income Tax should serve … Continue reading Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All
Revenue Procedure 2023-34 was released by the IRS on November 9, 2023. It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024
An earlier blog post explained how easy it is for the foreign person to fall into some nasty US tax traps when entering a foreign partnership with a US person. Even if that foreigner never sets foot in America and works solely from the foreign location, he can end up paying US taxes. In addition, … Continue reading Foreign Partnerships with a US Partner? Some Planning Ideas
Sometimes I like to bring up issues occurring strictly in the USA and take a peek at how the US tax rules would shake out if foreigners were involved in the transactions. It always makes for a much more complicated analysis. Here is one for today! Let’s look at the juicy story of Justice Clarence … Continue reading The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons!
You may remember from my last post that for the Swiss (I know them so well, being married to one for almost 4 decades), punctuality is not merely a nicety, or a bonbon in the huge dessert buffet of life. Punctuality is highly valued and de rigueur. So it is with the US tax rules when … Continue reading Tax Court Petition Filed Late? Taxpayer Beats the Clock with Third Circuit Decision
I’ve been married to a Swiss for almost 40 years. I know the critical importance of timeliness. When you say “I’ll be ready in 5 minutes”, believe me, that Swiss watch is ticking. And, so it is with the Tax Court and filing a Tax Court petition in response to an Internal Revenue Service (IRS) … Continue reading Is the US Tax Court Swiss? Taxpayer Loses When Petition Filed 11 Seconds Late
Last week I blogged about the US income tax issues that plague a US partnership when it has a foreign partner. That post showed things can get ugly when a US partnership has a foreign partner. The post got a lot of views and feedback so it is evidently a topic of interest. I thought … Continue reading Tax Things Get Ugly for Foreigners When a Foreign Partnership has a US Partner
When non-US persons invest in US assets, the investment structure should be considered well in advance. In many instances, foreign investors using US-based entities for investment are blissfully unaware of the tax pitfalls with regard to the structure chosen. The tax ramifications typically involve US income and US estate tax exposure. Foreign investors must nail … Continue reading Investing in a US Partnership? – A Bevy of Tax Issues for the Foreign Investor
My earlier post describing TikTok tax advice as to the magical workings of the “Non-Grantor Irrevocable Complex Discretionary Spendthrift Trust” (NGICDST) proved highly popular. The NGICDST is being marketed heavily on social media platforms and certain business websites. After the Internal Revenue Service (IRS) discovered the promotional material, the agency shut down any notion that … Continue reading TikTok’s (Wrong) Tax Advice and How the Trust Tax Rules Really Work
Part I of my blog post set out the background and discussed the debate over Internal Revenue Code Section 965 “transition tax” or “mandatory repatriation tax” enacted in 2017. The Supreme Court recently decided to review the 9th Circuit case of Moore v. United States bringing this controversial tax back into the spotlight. The Court … Continue reading Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More!
Virginia - US TAX TALK 