Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
Today’s post provides an update on some important US tax issues relevant to digital assets. While the Internal Revenue Service (IRS) continues its crackdown on digital asset tax reporting, the controversial broker tax reporting rules for digital assets have been postponed. It looks like we will be in for a wait! Today’s post provides the … Continue reading The Latest: Broker Reporting of Digital Assets and Deducting Crypto Losses
The United States Supreme Court has just set the stage for sky high FBAR penalties. How did this happen? Let's take a look - The case of United States v. Toth, No. 21-1009 (1st Cir. 2022) was on appeal to the US Supreme Court. The focus of the appeal was that the FBAR penalty was … Continue reading FBAR Penalties – US v. Molyneux and the Big Fat Money Grab
Today’s blog post looks again at the Report of Foreign Financial Accounts (Form 114), the well-known “FBAR”. It examines a case of first impression when it comes to finding a “willful” FBAR violation. Before delving into the case, I provide readers with a quick introduction to Mr. FBAR. The FBAR has its genesis in the … Continue reading Mr. FBAR Gets Bolder in Toth – “Deemed Willfulness” for FBAR Violation
United States v. Toth: Just yesterday, the United States Supreme Court denied review of Toth, a case being carefully followed by tax professionals who deal with FBAR cases, US persons abroad, and all things "foreign". Toth was an FBAR “willful” penalty case on appeal to the First Circuit, with one of the issues being whether … Continue reading Breaking! Gird Your Loins for Greater FBAR Penalties! Supreme Court Denies Review in Toth/ Excessive Fines Issue
Virginia - US TAX TALK 