Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Many children born overseas to a U.S. parent are U.S. citizens from birth. This is so even if the parents never registered the birth at a U.S. Consulate or Embassy, or applied for a U.S. passport for the child. Some parents view this as a way to keep the child outside the U.S. tax system, … Continue reading Born Abroad, American by Law: Should You Register Your Child?
When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property
Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!
The endorsement of an elective residence-based taxation model by former IRS Commissioner Charles Rettig and former IRS Commissioner Counselor Tom Cullinan, covered in my earlier Forbes article, has sparked important discussions about fairness for Americans abroad. Their piece highlights the burdens of America’s citizenship-based tax system and calls for a shift to treat expats more … Continue reading Residence-Based Taxation: Social Security, Pensions And 30% Withholding
Nearly a year ago, in the waning days of the 118th Congress, Representative Darin LaHood (R-IL) introduced a groundbreaking piece of legislation that sent ripples through the expatriate community and the international tax world: the Residence-Based Taxation for Americans Abroad Act (H.R. 10468). As I detailed in my earlier Forbes article, this bill represented a bold step … Continue reading Former IRS Leaders Endorse Residency-Based Tax For Americans Abroad
On September 19, 2025, the U.S. District Court for the Northern District of Texas upended IRS FBAR enforcement in United States v. Sagoo (No. 4:24-cv-01159, N.D. Tex. 2025). Sharnjeet Sagoo, a U.S. taxpayer with international ties, faced over $1 million in penalties for alleged willful failures of the Bank Secrecy Act requirement to report foreign … Continue reading The Sagoo Case: FBAR’s Reckoning In A Globalized World
On May 22, as the House of Representatives passed H.R. 1—the "One Big Beautiful Bill Act" (OBBBA)—by a 215-214 margin, I outlined the implications of Section 112029 of H.R.1 in my earlier Forbes article. The provision, "Enforcement of Remedies Against Unfair Foreign Taxes,” would have added a new Section 899 to the Internal Revenue Code. As … Continue reading Can Trump Revive The Revenge Tax By Executive Order ? OECD Delays Test G7 Deal
Lenders who advance cash to corporations often do so with a clear expectation: the company will repay the principal and will pay interest, and the borrower will report interest income. Yet for U.S. taxpayers the moment of truth comes much later, sometimes years after the money has left the bank—when the IRS, or a court, … Continue reading Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares
In recent months, several seemingly unrelated developments in U.S. law and policy have begun to converge in a way that should capture the attention of tax professionals, immigration lawyers, and globally mobile individuals. On one front, the Department of Justice continues to press denaturalization cases against U.S. citizens who obtained their status by fraud or … Continue reading USCIS Update: Citizenship, Denaturalization, Tax Compliance, Moral Character
Many non-Americans underestimate just how easily time spent in the United States can transform them into U.S. taxpayers. Under American tax law, you don’t need a U.S. passport or green card to face very significant IRS tax obligations. Simply spending enough days on U.S. soil may result in being classified as a “resident alien.” That … Continue reading Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist
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