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

Rich Americans…. Time to Wake Up!

Rich Americans (or foreigners with US assets), it's time to wake up and smell the coffee!  Why?  I am seeing more and more individuals with influence pushing for a change in the US tax laws so that wealth inequality becomes a thing of the past.  Whether you agree with this position is not the point … Continue reading Rich Americans…. Time to Wake Up!

Divorcing the United States: Two Methods – Renunciation and Commission of an Expatriating Act with “Intent”

This post is a sequel to "Expatriation – Giving up US Citizenship – Will I be Banned from Re-entering the USA?" my earlier blog post analyzing the so-called "Reed Amendment".  As discussed in that post, since the statutory language of the Reed Amendment applies only to those who “officially renounce” United States citizenship it may be … Continue reading Divorcing the United States: Two Methods – Renunciation and Commission of an Expatriating Act with “Intent”

Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?

Well, the numbers of individuals renouncing US citizenship is apparently reaching epic proportions.  It has been reported that 5,816 Americans gave up their citizenship in the first six months of 2020 and that this represents a 1,210% increase from the prior six months ending December 2019, when only 444 cases were recorded.  Most clients I … Continue reading Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?

Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health

Recently, I am seeing more and more married couples of dual nationality (with one US individual partner) struggling with the US tax issues wrought by such a "mixed marriage".  Some are same sex couples married under the laws of a foreign (non-US) jurisdiction.   Believe it or not, marriages taking place in a foreign country (whether … Continue reading Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health

Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now

The US gift tax is a tax imposed on the transfer of property by way of gift. The giver of the gift (the donor) is the party who must pay the tax.  Generally, any transfer to an individual without receiving something of equal value in return (measured in money or money's worth) is treated as … Continue reading Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now

Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test

Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE).  In addition they may be able to exclude certain amounts paid for foreign housing using the Foreign Housing Exclusion (FHE).  Both of these benefits are … Continue reading Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test

Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

On April  9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household”

Tax filing time is upon us! Selecting the best tax filing status is an important element of tax planning and should not be taken lightly.  For US persons who are married to foreigners (so-called "nonresident alien individuals", or "NRA"), special considerations come into play.  Making the decision how to treat your foreign spouse for US … Continue reading Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household”