Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Purchasing or owning real estate property overseas can be an exciting investment opportunity, but for U.S. persons, it comes with significant tax and reporting obligations. Foreign persons becoming U.S. tax residents (e.g., obtaining a green card) may already own overseas properties and should be aware of the U.S. tax issues they will face at the … Continue reading Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues
Foreign investors with assets in the United States often encounter complex estate tax rules that can significantly impact taxation of their U.S. assets at death. If the individual is a non-resident, non-citizen of the U.S. (NRNC), the U.S. estate tax applies only to assets situated or deemed to be situated within the U.S. (for example, … Continue reading U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens
If you are a US citizen or green card holder thinking about keeping or giving up your US status, tax professional, tax advisor, immigration consultant, enrolled agent, certified public accountant, family office, wealth advisor or wealth planner you should definitely attend this webinar. If you cannot attend, other options to obtain the webinar are available … Continue reading WEBINAR Expatriation & U.S. Tax Implications: Navigating Green Card (LTR) & Citizenship Relinquishment with IRS Final Section 2801 Transfer Tax Updates
The process for IRS to seize foreign assets to satisfy tax debts is not simple. IRS use of the so-called John Doe summons is often a first step to identify possible tax evasion with offshore assets, as noted in the recent case involving Trident Trust. After resolution of the tax matter, the IRS is faced … Continue reading Cross-Border Tax Collection: IRS Tools To Seize Foreign Assets
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
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
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
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
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
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”
Virginia - US TAX TALK 