Just in time for Christmas, we have two big gifts. Both relate to Malta Pension Plan schemes. If you are too busy to read the post because of the Christmas rush, in a nutshell, they've just been knocked out and the Internal Revenue Service (IRS) is hot on the trail for taxpayers who used them! … Continue reading Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..”
Author: us-tax.org
US Tax specialist based in Dubai since 2001. I am a member of the NYS Bar since 1984 and am admitted to the US Tax Court. My areas of specialty include US/international tax planning for US persons or foreign persons with any US connections; expatriation matters, regaining US tax compliance, voluntary disclosures, offshore accounts and assets, FATCA. Forbes Top 100 Must Follow Tax Twitter Account and Bloomberg Tax Professional to Follow on LinkedIn.
HELP! What to do When Foreign Law Impacts the US Tax Analysis of My Case?
Given today’s global economy it comes as no surprise that US taxpayers and the Internal Revenue Service (IRS) must increasingly consider the interactions between US and foreign laws when determining the US tax consequences of a particular transaction. In today’s world, it is no longer possible for practitioners to ignore the possible implications of another … Continue reading HELP! What to do When Foreign Law Impacts the US Tax Analysis of My Case?
Is IRS Finally Seeing the Light on Foreign Information Returns?
Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published December 3, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com published in Tax Insights and Commentary News, online here. Various options are available to correct the problem of missing information returns for U.S. … Continue reading Is IRS Finally Seeing the Light on Foreign Information Returns?
Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out
Today’s post looks at the case of Rost v United States, No 119-CV-0607-RP 2021 BL 435976 (WD Tex., Austin Div., September 22, 2021). In the Rost case, the Internal Revenue Service ("IRS") assessed close to USD597,000 in civil penalties for a US taxpayer’s failure to file IRS Forms 3520 and 3520-A, information reporting with regard … Continue reading Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out
Americans Abroad: Sale of “Principal Residence”, Gain Exclusion, Unforeseen Circumstances & COVID-19
Section 121 of the US Internal Revenue Code allows for the exclusion of up to $250,000 ($500,000 for a married couple filing jointly) in gains arising from the sale of a "principal residence." The exclusion applies whether the residence is located Stateside or overseas. The tax law has very specific rules. Aside from the fact that … Continue reading Americans Abroad: Sale of “Principal Residence”, Gain Exclusion, Unforeseen Circumstances & COVID-19
IRS Determined to Collect FBAR Penalties – “We Have Ways of Making You Pay” … Even if Your Money is Outside the US
The case of US v Schwarzbaum (decided October 26, 2021), discussed in today’s blog post, serves as a harsh reminder of how far the US government will go to collect FBAR penalties. The importance of posting about this latest development is to underscore how aggressive FBAR penalty collection efforts are now becoming. Of course, this case … Continue reading IRS Determined to Collect FBAR Penalties – “We Have Ways of Making You Pay” … Even if Your Money is Outside the US
Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
Last week's blog post looked at one way that a non-US citizen can become subject to US income tax on his or her worldwide income - simply by getting a US green card. Today's post looks at the other way one can fall into the US tax trap. “Substantial Presence” in the US An individual … Continue reading Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
US “residents” are subject to tax on income derived from all sources. That means they are subject to tax on their worldwide income regardless of the source of that income. So, for example, dividends earned from a French company are taxable, as is gain on the sale of rental property located in Hong Kong; prize money won … Continue reading Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
IRS Made a Big Announcement – So, Can a Taxpayer Now Rely on IRS FAQ’s?
Despite the Internal Revenue Service (IRS) recent announcement, it seems to me that the answer is still “Well, it depends!” Here’s my take on the what the IRS said, which to be honest, was just a bit more clear than mud. Taxpayers and tax pros should always look first to whether the FAQ is published … Continue reading IRS Made a Big Announcement – So, Can a Taxpayer Now Rely on IRS FAQ’s?
Working Overseas? What Happens with Your U.S. Social Security?
US Social Security and Medicare taxes continue to apply to wages for services performed as an employee working outside of the United States if you are working for an “American employer”. Similarly, if you are abroad and you are a self-employed US citizen or resident you generally are subject to the so-called “self-employment tax”. Self … Continue reading Working Overseas? What Happens with Your U.S. Social Security?
Virginia - US TAX TALK 