Today’s post involving the case of Jonathan Zuhovitzky presents some important takeaways: The IRS can get very aggressive when it comes to assessing “willful” FBAR penalties. We see this trend is on the rise. A diligent representative, however, can get the IRS to settle an FBAR matter that is favorable to the taxpayer. It takes … Continue reading Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely
Many parents establish a trust for their children and intend that the trust be a domestic (US) trust. Often, this will be a testamentary trust. That is, one that comes into being upon death of the testator, created pursuant to a Last Will & Testament. Many parents struggle with the decision as to who to … Continue reading Selecting a Trustee for Your US Trust – What About a Foreign Family Member?
On November 8, 2020, I participated in a podcast with attorney John Richardson. We discussed some of the reasons why the incoming administration was likely to increase the pressure on Americans abroad. The podcast is here. On March 25, 2021 the Senate Finance Committee held a hearing on International Taxation. The hearing discussed changes to … Continue reading GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon
COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel
Looking to live under the Tuscan sun? Dreaming about Dubai? The pandemic has had many people considering a move. Many are looking at a move abroad. Kelly Phillips Erb, the @TaxGirl and I (@VLJeker , the @TaxLady_w_Style) had a great conversation about what it means from a tax and practical perspective for a US person … Continue reading Thinking of Moving Abroad? Here’s the Scoop with the Tax Girl and the Tax Lady
Since the passage of the Foreign Account Tax Compliance Act (FATCA) in 2010, we’ve been inundated with mountains of information about this legislation including its implementing Treasury Regulations, Internal Revenue Service (IRS) announcements and notices, reams of articles, books, blog postings as well as a Twitter-verse awash with FATCA-esque tweets. Following FATCA’s roll-out, hordes of … Continue reading FATCA 11 Years Later – US Still the Tax Haven?
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation
UPDATE: Sadly - the US Consulate in Dubai has just informed me that they cannot accept appointments for non-emergency services for non-UAE residents. Expatriation is considered a non-emergency to them, although I feel sure the individual wishing to expatriate would disagree. I have requested the Consulate to update me if the situation changes. Welcome … Continue reading Dubai: Combine your Renunciation with a Vacation
The Internal Revenue Service (IRS) just issued Notice 2021-18. This is the geographical list that spells out adjustments to the foreign housing exclusion available for many US persons living abroad. These limitations are made on the basis of geographic differences in housing costs relative to housing costs in the United States. The ability to deduct … Continue reading Where Do You Live? IRS Announces 2021 Foreign Housing Cost Amounts