BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead

IRS literally just finalized the Code Section 2801 regulations on January 10. These long-awaited final regulations concern gifts and bequests received by a U.S. person from foreign persons who were former U.S. citizens or green card holders who qualified as "long term residents" and were "covered expatriates" at the time of giving up their U.S. … Continue reading BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead →

Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons →

Breaking! Residence-Based Taxation for Americans Abroad May Become Reality

Representative Darin LaHood just introduced on December 18 the Residence-Based Taxation for Americans Abroad Act, aiming to modernize the US tax system for Americans living overseas. This proposal seeks to shift from the current citizenship-based taxation—which taxes US citizens on their worldwide income regardless of residence—to a residency-based system. The existing US tax framework has … Continue reading Breaking! Residence-Based Taxation for Americans Abroad May Become Reality →

Cross-Border Transactions: Foreign Laws And U.S. Tax In A Borderless World

In today’s interconnected world, borders blur while regulations multiply. Families span continents, careers pivot across countries, and even currencies like Bitcoin redefine value. Meanwhile, the U.S. tax system casts an ever-wider net, taxing its citizens on worldwide income regardless of where they reside. Through measures like the Foreign Account Tax Compliance Act, the U.S. government … Continue reading Cross-Border Transactions: Foreign Laws And U.S. Tax In A Borderless World →

Late Form 3520 Foreign Gifts And Bequests, Good News From IRS

The IRS Commissioner Danny Werfel announced some good news for taxpayers at the end of October 2024. The IRS has ended its practice of automatically assessing penalties when a taxpayer voluntarily submits a late Form 3520, Part IV. This form deals with the obligation of U.S. persons to report to the IRS the receipt of … Continue reading Late Form 3520 Foreign Gifts And Bequests, Good News From IRS →

Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax” →

Cracking The Code On FBAR Penalties: IRS Collection Hurdles Explained

The Financial Crimes Enforcement Network, FinCEN Form 114, Report of Foreign Bank and Financial Accounts, is a crucial yet frequently misunderstood requirement for U.S. persons with foreign financial accounts. The FBAR may be familiar to many Americans living abroad, but it remains largely unknown to many U.S.-based individuals who might still have an obligation to … Continue reading Cracking The Code On FBAR Penalties: IRS Collection Hurdles Explained →

Americans Living Abroad: Foreign Housing Tax Break, Explained

Overseas Americans are entitled to certain tax breaks assuming various qualifications are met. One of the significant tax breaks is the ability to exclude from taxable income certain amounts provided by an employer for foreign housing. Housing costs are “personal” in nature and the tax laws do not provide exclusions or deductions for personal expenditures. A … Continue reading Americans Living Abroad: Foreign Housing Tax Break, Explained →

Giving Up US Citizenship – The Path Gets More Complex As DS-4079, Now 18 Pages, Is Revamped

The new procedure for obtaining a Certificate of Loss of US Nationality (CLN) effective November 1, 2024, revolves around an updated Form DS-4079. This "redesigned" form now has tailored sections for different types of expatriating acts, reflecting a more specific and perhaps a more streamlined approach to processing renunciations and relinquishments. Briefly, US citizenship can … Continue reading Giving Up US Citizenship – The Path Gets More Complex As DS-4079, Now 18 Pages, Is Revamped →

WEBINAR 2 IRS CPE -Global Workforce: U.S. Tax Impact on Digital Nomads, Remote Workers and Their (Often Overlooked) Employers

Some exciting news. I am presenting a webinar on Nov. 21 Thursday 10 AM EST. 2 IRS CPE credits. $20 off on registration fee if you use code "VIRGINIA" at checkout Hope to see you there. Please share with your colleagues and friends who may have interest in this topic. REGISTER AT THE LINK: Global … Continue reading WEBINAR 2 IRS CPE -Global Workforce: U.S. Tax Impact on Digital Nomads, Remote Workers and Their (Often Overlooked) Employers →