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” →

Business & Investment Structuring Between the USA and UAE

Please pass this along to your friends and colleagues who may have an interest. The International Business and Structuring Association is hosting an event where I, along with other industry leaders, will be covering the unique challenges and opportunities faced by businesses and investors engaged in cross-border transactions between the US and UAE. I hope … Continue reading Business & Investment Structuring Between the USA and UAE →

Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light?

The Internal Revenue Service (IRS) - starting to see some light with respect to "foreign" pension plans? The US tax issues surrounding foreign pensions and retirement schemes is extremely complex and has vexed tax professionals and US persons abroad for many years. (Read my earlier blog post here). Due to the diversity of such plans, … Continue reading Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light? →

Expatriated? But Failed to File Form 8854? IRS Provides a Fix!

2020 looks promising in more ways than one. First, on a professional level I was delighted and proud to be named, for the 4th year running, to Forbes Top 100 Must Follow Tax Twitter Accounts for 2020. Please do encourage your friends and colleagues to follow me on Twitter and to subscribe to my US … Continue reading Expatriated? But Failed to File Form 8854? IRS Provides a Fix! →

Cryptocurrency and Your 2019 Tax Return – Handle With Care

It’s been no secret that cryptocurrency is in the crosshairs of the Internal Revenue Service (IRS). Virtual currency is one of the IRS “campaigns” and criminal investigations related to crypto already started last year. Taxpayers are being sent “educational” letters to remind them and warn them of their tax obligations when it comes to the … Continue reading Cryptocurrency and Your 2019 Tax Return – Handle With Care →

Dangerous Liaisons: Foreign Assets and the US Nominee

We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by financial institutions that were the subject of non-prosecution agreements, as well as examining treasure troves of financial information from various leaks (think “Panama Papers”) looking not only for tax dollars, interest and penalties but … Continue reading Dangerous Liaisons: Foreign Assets and the US Nominee →

US Beneficiary of Foreign Trust: Understanding US Tax Filings

I have written a series of blog posts about foreign (i.e., non-US) trusts and the US tax issues associated with them including the US tax filing and reporting requirements for each of the different players in the foreign trust scenario (creator or "grantor"/"settlor" of the trust), the trustee; and today, the US beneficiary. One of … Continue reading US Beneficiary of Foreign Trust: Understanding US Tax Filings →