Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
Thinking of moving overseas, or already living abroad as an American? One thing you can’t escape is U.S. taxes. In this video, I sit down with Jahtna Hernandez to discuss the unique challenges Americans face under a citizenship-based tax system, and the key rules every expat, retiree, or digital nomad needs to know in 2025. … Continue reading What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025
Imagine over the years that you’ve built a nest egg in a U.S. Individual Retirement Account, Roth IRA, or Simplified Employee Pension IRA. This is a common scenario for many U.S. citizens and green card holders while working in the United States. In a scenario that is becoming increasingly more common, imagine that after years … Continue reading U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card
Recent headlines have created alarming concerns among naturalized U.S. citizens. These have suggested that certain tax issues could lead to the loss of U.S. citizenship. This fear is now being amplified on various platforms and stems from a case involving, Vanessa Ben, a Houston woman facing denaturalization over her admission of tax fraud prior to … Continue reading Tax Fraud And Denaturalization Risks: A Balanced View For Taxpayers
While a campaign promise by President Donald Trump to eliminate income taxes on Social Security benefit income was not fulfilled, seniors were granted certain relief. The landmark tax legislation, the One Big Beautiful Bill Act (H.R. 1), signed into law on July 4, 2025 introduced a temporary special deduction for taxpayers aged 65 or older. The Social Security Administration … Continue reading A Tale Of Two Retirees: New Senior Tax Deduction And Foreigners’ Social Security
Artificial intelligence tools such as ChatGPT and Grok are becoming household fixtures with Americans increasingly turning to them. These tools are being used to find answers on everything from cooking recipes to complicated tax questions. How reliable is AI for taxpayers seeking tax advice, particularly on U.S. international tax issues? While AI has laudable capabilities … Continue reading The Danger Of Relying On AI For U.S. Tax Advice
Virginia - US TAX TALK 