Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Sometimes an individual will come to me with a pesky problem – they have filed a tax return, but it fraudulently omitted income. Typically, a lot of income. Typically, from foreign sources. Always, in hopes the omission will go unnoticed by the IRS. The thinking is along the lines that since the omission involves foreign … Continue reading Too Little, Too Late: Fixing the Fraudulent Tax Return
Very few US Estate tax returns are actually filed by the estates of nonresident alien individuals. Statistics indicate that the amount of Estate Tax earned by the US Government on such returns is quite small. The cost of structuring to avoid the tax is probably of far greater magnitude than what is collected by the US … Continue reading All the Fun Rules — US Estate Tax for Nonresident Alien Individuals
US persons (e.g., US citizens, US green card holders) must make an information report to the IRS when making certain transfers to foreign (non-US) corporations. Specifically, when a US person transfers (or is treated under the tax rules as having transferred) property to a foreign corporation in certain “non-recognition” transactions (e.g., a contribution of capital … Continue reading Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926
Henry Seggerman has first-hand experience with this type of situation. Without hesitation, my guess is that he’ll tell you to get the Estate into an IRS Voluntary Disclosure Program (“VDP”). Here is the tale of the unenviable case of the Seggermans! Henry was the son of a prominent New York businessman who passed away. Henry was … Continue reading What if Someone Dies Owning an Undeclared Foreign Financial Account? What Should The Executor & Heirs Do?
Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends". It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Part I, Part II and below, Part III. Unsurprisingly, many US owners of corporations that are … Continue reading Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations”
Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends". It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Access links here Part I, Part II (which appears below) and Part III. Unsurprisingly, many US owners of corporations … Continue reading Dividends from Foreign Corporations Part II – “Controlled Foreign Corporations”
Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends". It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Below is Part I, and you can access the remaining posts at these links Part II and Part III. … Continue reading Dividends From Foreign Corporations – Understand Your Investment! PART I
Copied below is my post as it appeared (March 21 2018) on my former blog "Let's Talk About US Tax" when hosted by Anglo Info. By now I suspect many of my readers have heard about (and are shedding tears over) new Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by … Continue reading Section 965 “Transition Tax”: It’s Time to Pay the Piper
Below is a copy of my post as it appeared (May 21 2018) on my former blog "Let's Talk About US Tax" hosted by AngloInfo. We had a very interesting case decided May 16 2018 when a district court in Texas granted Dominique Colliot’s motion for summary judgment (United States, v. Dominique G. Colliot). The … Continue reading Can You Claim a Refund of Your “Willful” FBAR Penalty?
Compliance with the Foreign Account Tax Compliance Act (“FATCA”) enacted 8 years ago, has resulted in a plethora of new US tax reporting requirements, forms and rules. Unfortunately, all of these continue to evolve and become more and more complex with the passage of time. The year 2014 marked a significant year for the Form W-8BEN, a … Continue reading Confused Yet? W-8BEN, W-8BEN-E, Foreign ITINs and Dates of Birth
Virginia - US TAX TALK 