WEBINAR Expatriation & U.S. Tax Implications: Navigating Green Card (LTR) & Citizenship Relinquishment with IRS Final Section 2801 Transfer Tax Updates

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

Cross-Border Tax Collection: IRS Tools To Seize Foreign Assets

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

Breaking! Residence-Based Taxation for Americans Abroad May Become Reality

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

Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

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”

Giving Up US Citizenship – The Path Gets More Complex As DS-4079, Now 18 Pages, Is Revamped

The new procedure for obtaining a Certificate of Loss of US Nationality (CLN) effective November 1, 2024, revolves around an updated Form DS-4079. This "redesigned" form now has tailored sections for different types of expatriating acts, reflecting a more specific and perhaps a more streamlined approach to processing renunciations and relinquishments.  Briefly, US citizenship can … Continue reading Giving Up US Citizenship – The Path Gets More Complex As DS-4079, Now 18 Pages, Is Revamped

Need an FBAR Escape Hatch?

The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for US persons (citizens, green card holders and those meeting the substantial presence test) with foreign financial accounts. With the deadline for the 2023 FBAR set for October 15, my Forbes article provides information to … Continue reading Need an FBAR Escape Hatch?

IRS Commitment To Assist International And Overseas Taxpayers

As indicated in its responses this summer to several key recommendations from the Taxpayer Advocate Service, the IRS is making strides towards enhancing the taxpayer experience. Among these, significant attention is being given to improving services for international and overseas taxpayers, a group that has faced unique challenges and severe penalties. This article highlights IRS responses … Continue reading IRS Commitment To Assist International And Overseas Taxpayers

Accidental Americans Learning They Are Citizens Face A Tax Dilemma

As some of my readers know, I am now a contributor writing on Forbes.  My coverage area is US international tax law for overseas Americans and foreigners.  My article is copied below. It first appeared on Forbes April 9, here. Don't miss out on my informative and easy-to-understand US tax content - Follow me on … Continue reading Accidental Americans Learning They Are Citizens Face A Tax Dilemma

IRS E-Filing Plan: No Solution for the Overseas American

The Internal Revenue Service (IRS) has been examining the possibility of a direct e-filing system. Can you imagine that bypassing tax preparation software or return preparers and direct filing with the IRS may be on the horizon? The IRS’s contemplated plan would enable users to directly prepare and file their tax returns with the U.S. … Continue reading IRS E-Filing Plan: No Solution for the Overseas American

Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All

If you or your clients are really (really) wealthy (more than $100 million in annual income or more than $1 billion in assets) and thinking about expatriation (relinquishing US citizenship or a green card as a long-term resident), the time is now.  Even if not super wealthy, the newly proposed Billionaires Income Tax should serve … Continue reading Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All