Category: Accidental Americans

Constitutionality of NIIT and Passport Revocation Rules Stand: Taxpayers Sacrificed in US Supreme Court and Tax Court  

The US Supreme Court and the Tax Court issued two big decisions impacting many US individual taxpayers. Here’s a short and not-so-sweet summary of what went down: The 3.8% Net Investment Income Tax Stands On June 17, 2021, by a clear majority vote,  the Affordable Care  (ACA) was upheld by the US Supreme Court, including … Continue reading Constitutionality of NIIT and Passport Revocation Rules Stand: Taxpayers Sacrificed in US Supreme Court and Tax Court   →

All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It

Under current law, limited partners who materially participate in a partnership's business are not subject to self-employment tax. Members of an S corporation who materially participate in the S corporation's business are subject to self-employment tax only on "reasonable compensation" received in their capacity as an “employee”. These individuals are also exempt from the 3.8% … Continue reading All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It →

Pres. Biden: 3d Party Information Reporting to be Increased – Foreign Accounts and Crypto Included

President Biden has an economic agenda and a big part of it is strengthening taxpayer compliance by increasing what must be reported to the Internal Revenue Service (IRS) about client accounts by third party financial institutions and similar entities. The President’s proposal would require information reporting on both business and personal financial accounts. The reporting … Continue reading Pres. Biden: 3d Party Information Reporting to be Increased – Foreign Accounts and Crypto Included →

Closing the International Tax Gap: IRS Doing Virtually Nothing With FATCA

Today’s blog post discusses the overall and international tax gaps, takes a look at the offshore world and how enforcement of the tax laws is faring (hint - not so good). It summarizes some important testimony given on May 11, 2021 by the Honorable J. Russell George, Treasury Inspector General for Tax Administration before the … Continue reading Closing the International Tax Gap: IRS Doing Virtually Nothing With FATCA →

Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel

COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel →

What does Senator Warren’s Proposed Wealth Tax Mean for You?

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You? →

Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation →

Dubai:  Combine your Renunciation with a Vacation  

UPDATE:  Sadly - the US Consulate in Dubai has just informed me that they cannot accept appointments for non-emergency services for non-UAE residents.  Expatriation is considered a non-emergency to them, although I feel sure the individual wishing to expatriate would disagree. I have requested the Consulate to update me if the situation changes.   Welcome … Continue reading Dubai:  Combine your Renunciation with a Vacation   →