Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Taxpayers have often struggled with shifting tax filing deadlines and complex IRS penalty calculations. But if some of those filing deadlines were legally postponed by an act of Congress, certain penalties and refund interest may have been incorrectly calculated by the IRS, entitling impacted taxpayers to relief. A recent federal court case may offer some … Continue reading Kwong Case: IRS May Owe You Money, Cut Penalties
Right before the U.S. tax filing season officially opened on January 26, the Internal Revenue Service announced significant leadership changes that have drawn cautious scrutiny from tax professionals. Practitioners with the high-net-worth clients and those who assist Americans living abroad are paying close attention. While IRS leadership transitions regularly occur, the timing and substance of … Continue reading IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?
Most people assume that once they have qualified for Social Security based on their U.S. earnings, their monthly benefit will follow them anywhere in the world for life. This is true for U.S. citizens. But for non-U.S. citizens, including former U.S. citizens and former green-card holders, the rules are very different. These individuals are classified … Continue reading Some Foreigners Can’t Receive U.S. Social Security Abroad: Understanding SSA Country List 2
The Internal Revenue Service has released the final version of Form 708, titled “United States Return of Tax for Gifts and Bequests Received from Covered Expatriates,” (revision dated December 2025) along with detailed draft instructions (revision dated December 2025). As of today’s publication, the accompanying instructions remain in draft form available only as a draft … Continue reading IRS Drops Form 708: 40% Tax, Gifts & Bequests, “Covered Expatriates”
I have previously written how changes to U.S. citizenship and expatriation rules often produce consequences far beyond what legislators appear to anticipate. Whether in the tax arena or in the administration of federal benefits, citizenship status functions as a foundational legal concept, not a standalone policy. Senator Moreno’s proposed “Exclusive Citizenship Act” underscores this point. … Continue reading Exclusive Citizenship Act: Unintended Consequences Continue To Emerge
One email from a tribal member sparked today’s article. A Native American reader of my recent Forbes piece on Senator Bernie Moreno’s Exclusive Citizenship Act of 2025 wrote in with a simple, powerful question: “How would this affect us?” In fewer than 10 words, that message prompted me to dig much deeper. What follows is … Continue reading Moreno’s Fast-Track Citizenship Bill: Tax & Social Security Bombs, Diplomatic Chaos & More
The United States along with over 70 other countries has adhered to the Joint Statement on the OECD’s Crypto-Asset Reporting Framework, “CARF”. CARF is the digital-asset counterpart to the Common Reporting Standard “CRS” that has exchanged bank and securities account data among signatory countries (now well over 100 countries). The United States has formally indicated … Continue reading Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF
On December 1, 2025, Senator Bernie Moreno (R-OH) introduced the Exclusive Citizenship Act of 2025. The bill would prohibit any person from simultaneously holding U.S. citizenship and citizenship of another country. The major provisions include: An effective date 180 days after enactment. The requirement that existing dual citizens would have one year to renounce all … Continue reading Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship
In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory
Each year, thousands of children are born overseas to one U.S. citizen parent and one non-U.S. parent. Under U.S. immigration law, many of these children are U.S. citizens from birth, provided the American parent satisfies a relatively simple test: at least five years of physical presence in the United States, with two of those years … Continue reading Unregistered U.S. Citizenship: Hidden Risks For American Born Abroad
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