Tax Break 2022 – Don’t Be Sad

On vacation! Catch up to you next week with my usual Thursday blog post.

Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments?

Many Americans living abroad purchase properties in their foreign country of residence. They often accomplish this with financing from a financial institution located in the country where the property was purchased. Later, they may return to the US and continue holding the property and meeting their mortgage payments. Similarly, many non-US citizens purchase properties with … Continue reading Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments? →

Tax Planning – Ownership of Foreign Real Property

Investment decisions are difficult nowadays, but I am still getting inquiries from US persons about the US tax effects of owning foreign real property. Tax efficient structuring depends on numerous factors. While an earlier blog post discussed the general concept of what is called a "disregarded entity" and how it is used (and misused) by … Continue reading Tax Planning – Ownership of Foreign Real Property →

LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP

Join the webinar on August 23 Tuesday at 12 noon EDT. Register here Tax pro's: A new line of business awaits if you are prepared to explain the expatriation process, assist with the various Department of State forms, provide guidance to handle the State Department interview, to approach the written statement of reasons for expatriation … Continue reading LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP →

Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?

Part I of this blog post examined the US tax issues faced by the Duke of Sussex who moved with Duchess Meghan to Los Angeles in March 2020. Given the significant number of days of physical presence in America, Prince Harry has most likely already met the "substantial presence test" and is being taxed the … Continue reading Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family? →

Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?

There are good lessons in today's post for any individual who is considering attaining "US status" - be it by obtaining a green card, US citizenship or through extended physical presence in America. The lessons are explained in detail in a 2-part blog post and will be helpful to Prince Harry who may possibly take … Continue reading Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family? →

Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA

Over my many years of international tax practice, I regularly come across the loving foreign parent (or relative) with a child (or other relation) residing in the United States. The individual may be studying there or living there and pursuing the American dream - starting a business or perhaps buying a home. He or she … Continue reading Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA →

Is the IRS Being Reasonable when it comes to “Reasonable Cause”?

My recent blog post discussed how I approach “streamlined procedure” filings for taxpayers with unreported income, for example, from offshore assets or accounts. Often, the tax noncompliance for such cases involves unfiled international information returns as well. As discussed in the blog post, I draft the required statement of non-willfulness in such a manner that … Continue reading Is the IRS Being Reasonable when it comes to “Reasonable Cause”? →

IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates

The Treasury Inspector General for Tax Administration (TIGTA) has been documenting some careless work being carried out by the Internal Revenue Service (IRS). We have the most recent TIGTA report (Number 2022-40-036) of May 4, 2022 reporting that the IRS destroyed 30 million “paper-filed information return documents” without bothering to process them beforehand. This destruction … Continue reading IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates →

FBAR Penalty & the US Supreme Court: If the Penalty is “Per Form”, are “Per Account” Penalty Refunds Possible?

My earlier blog posts discussed the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” rather than “per form” basis. The Fifth and Ninth circuit courts disagree on the statutory interpretation of the Bank Secrecy Act (BSA) (31 U.S.C. § 5321(a)(5)(B)(i)), particularly what constitutes … Continue reading FBAR Penalty & the US Supreme Court: If the Penalty is “Per Form”, are “Per Account” Penalty Refunds Possible? →