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
Well, if my dream last night has anything to do with reality, the world is in for a big shakeup. In my dream, President Trump came to me for US tax advice on expatriation - that is giving up one's US citizenship (or, green card in the case of long term residents). What a bizarre … Continue reading President Trump – Expatriating?
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
Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”). My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”. In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)
Many Americans living and working overseas are involved in charitable causes. The question often arises whether US expats living abroad can obtain the tax benefit for a charitable contribution deduction? The answer depends on various factors, including those discussed below. Where is the Charity Organized or Created? The mere fact that a US taxpayer is … Continue reading Year End Tax Planning: Making Charitable Contributions if You are an American Abroad
Cryptocurrency (such as Bitcoin) is a type of virtual currency. It is an emerging area, and as such, comes with an enormous amount of uncertainty when it comes to the US tax treatment of transactions involving its use. On October 9, the Internal Revenue Service (IRS) issued Revenue Ruling 2019-24 providing much awaited guidance about … Continue reading IRS Cryptocurrency Update: Taxing Those”Hard Forks” and “Air Drops”
Moving is always a stressful event and it is easy for certain things to be overlooked. One item on your moving checklist that is critical to remember: properly notifying the Internal Revenue Service (IRS) of your change of address. Today's post tells you how to do it right and the terrible things that can happen … Continue reading Is the IRS Trying to Find You?
Here in the Middle East where I have been practicing for almost two decades, I have seen that it is very common for families to create offshore structures in various countries (outside the USA) to hold a large portion of the family wealth. The underlying reasons for maintaining these structures outside of the family’s home … Continue reading OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)
For today's post, let me start with the Conclusion! If you expatriate after June 16, 2008 and you fail to file Internal Revenue Service (IRS) Form 8854 (Initial and Annual Expatriation Statement), you DO NOT have continued US income tax liability on your worldwide income. It's that simple. You may have read or heard otherwise … Continue reading FALSE! Failure to File Form 8854 Means Continued Liability for US Tax on Worldwide Income
Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one is a US person and they are impacted by application of a foreign country’s community property laws. You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!