Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
The title of this post could also be “What a Difference a Day Makes”. Most of my readers are quite familiar with the expatriation regime, as I have written many blog posts on this topic. Before delving into the question of the date to use when working through Form 8854, let’s have a quick review … Continue reading Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?
In Fairbank v. Commissioner, T.C. Memo. 2023-19, Dkt. No. 13400-18 (February 23, 2023) the Internal Revenue Service (IRS) issued a notice of deficiency in April 2018 for taxable years 2003, 2004, 2005, 2006, 2007, 2008, 2009, and 2011. The taxpayers argued the IRS could not go back to these prior years, challenging the assessments on … Continue reading FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003
With tax season in full swing, now is a good time to review the various civil statutes of limitations (SOL) rules that apply to US tax matters. Perfect timing to review because we also have a Tax Court case from last month showing how harsh the consequences of the SOL can be if a taxpayer … Continue reading Tax Statutes of Limitation – Run Fast, IRS is Right Behind You
On March 15, I was delighted to present cross-border tax topics of interest for the Financial Planning Association (FPA). FPA is a well-known membership organization for certified financial planner professionals and those engaged in the financial planning process. It provides its members with practice support, learning, advocacy, and networking. As a tax professional, with 40 … Continue reading Free for You: My Cross-Border Tax Presentation for the Financial Planning Association
Last week I blogged about how the US tax system can create serious tax problems for the international couple when one is a US person and the other is not. In order to keep things simple, it is often advised that the couple hold assets separately to avoid nasty US tax complications. However, in some … Continue reading The Perfect Storm – US Tax, Community Property & the Mobile International Couple
Readers of my blog know from previous posts (for example here and here) that unless the international couple enjoys dealing with complicated US tax matters and filings, holding title to assets jointly with a non-US citizen spouse is risky business! The well-advised keep their assets completely separate to avoid nasty US tax complications. However, this alone … Continue reading The US Tax Trap: International Marriage, Community Property and the Mobile Couple
It has been the position of the Internal Revenue Service (IRS) that a “Report of Foreign Bank and Financial Accounts” (Form 114), commonly called the “FBAR”, must still be filed to report any foreign accounts, despite a green card holder’s treaty tie-breaker claim. It came as a big surprise to me that the United States … Continue reading Treaty Tie-Breaker is an FBAR Escape Hatch, Says the Court!
What we have all been waiting for! Bittner v. United States was just decided hours ago by the United States Supreme Court! An amazing taxpayer win. It is late here in the Middle East, so I provide only the information you need to know! You can read the full case here. The Bank Secrecy Act … Continue reading BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account
Digital assets and FBAR reporting are definitely on the horizon but as yet, have not arrived. With the various announcements by the Internal Revenue Service (IRS) that focus on the proper tax reporting for digital assets, as well as delaying implementation of third party broker reporting, it makes total sense that the Financial Crimes Enforcement … Continue reading Digital Asset Reporting for Mr. FBAR @FinCEN
A survey conducted by CoinLedger of US crypto crypto investors found that only 58% of the sample size reported crypto holdings on their taxes in 2022. That was an improvement of 4% year-over-year. Meanwhile, 31% did not report (11% would not answer). Let's look at the non-reporters: 50% said the primary reason was that they … Continue reading More of the Latest: Digital Asset Reporting for Mr. Taxman @IRS
Virginia - US TAX TALK 