Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days

Why should I blog about a possible wealth tax in California? After all, my US tax blog focusses on international tax matters, US persons abroad, and foreign families with any US connections.  Well, for starters, many of my clients are foreign nationals who (prior to COVID-19) enjoy visiting the US, or have specialized medical treatment … Continue reading Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days

US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust

Many individuals have questions about the US tax consequences of foreign (non-US) assets inherited from a non-US individual who has passed away. They want to know whether US tax reporting is required, or if they must pay US tax on the inheritance. Some ask about the US tax upon a later sale of the inherited … Continue reading US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust

MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad

Merry Christmas to all of my readers and followers who celebrate this special time of year. I hope the joy of the season will follow you into the New Year. Sadly, Christmas won’t be merry for many Americans abroad who are ensnared in the grip of “FATCA,” the notorious “Foreign Account Tax Compliance Act”.  Briefly, … Continue reading MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad

What a Mess: Debt Forgiveness and the American Abroad  

Imagine you are an American taxpayer living overseas. Like so many other Americans you are facing financial hardships wrought by COVID-19.  You have a car loan you cannot pay and mounting credit card debt. Like an angel from above, your creditors agree to forever forgive some of the amounts you otherwise owe them.  You cannot … Continue reading What a Mess: Debt Forgiveness and the American Abroad  

IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement

On November 5, the Internal Revenue Service (IRS) made life more difficult for taxpayers who may have missed some foreign information return filings.  The IRS quietly revised one of the four options to correct for missing information returns with respect to a US taxpayer’s interest in any offshore/foreign assets and holdings (e.g., Form 8938, Form … Continue reading IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement

Expatriation: More than just a Fashionable Trend — Numbers Climb

The number of individuals ending their US status, or “expatriating” continues to rise unabated.  “Expatriates” as used in this context refers to citizens renouncing US citizenship or “long term residents” giving up a green card.  On October 28 the Treasury Department released the names of 732 individuals who “expatriated” during the third quarter of 2020. When … Continue reading Expatriation: More than just a Fashionable Trend — Numbers Climb

Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time.  This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR).  Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS

The Internal Revenue Service (IRS) is looking for money.  As part of the hunt, it has instituted various “campaigns” (full list here) aimed at areas in which there is greater taxpayer noncompliance that may involve significant tax dollars and penalties. One such campaign involves the failure by a US person to file complex information-reporting tax … Continue reading Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS

Expatriation – IRS Told to Get Tough and Enforce the Law

The Treasury Inspector General for Tax Administration (TIGTA) recently issued its report “More Enforcement and a Centralized Compliance Efforts Are Required for Expatriation Provisions”, (Reference Number: 2020-30-071, September 28,2020) telling the Internal Revenue Service (IRS) that it needs to do more to make sure that the rising number of US citizens and long term residents … Continue reading Expatriation – IRS Told to Get Tough and Enforce the Law