Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024

Revenue Procedure 2023-34 was released by the IRS on November 9, 2023. It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024 →

The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons!

Sometimes I like to bring up issues occurring strictly in the USA and take a peek at how the US tax rules would shake out if foreigners were involved in the transactions. It always makes for a much more complicated analysis. Here is one for today! Let’s look at the juicy story of Justice Clarence … Continue reading The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons! →

Tax Court Petition Filed Late? Taxpayer Beats the Clock with Third Circuit Decision

You may remember from my last post that for the Swiss (I know them so well, being married to one for almost 4 decades), punctuality is not merely a nicety, or a bonbon in the huge dessert buffet of life. Punctuality is highly valued and de rigueur. So it is with the US tax rules when … Continue reading Tax Court Petition Filed Late? Taxpayer Beats the Clock with Third Circuit Decision →

Is the US Tax Court Swiss? Taxpayer Loses When Petition Filed 11 Seconds Late

I’ve been married to a Swiss for almost 40 years. I know the critical importance of timeliness. When you say “I’ll be ready in 5 minutes”, believe me, that Swiss watch is ticking. And, so it is with the Tax Court and filing a Tax Court petition in response to an Internal Revenue Service (IRS) … Continue reading Is the US Tax Court Swiss? Taxpayer Loses When Petition Filed 11 Seconds Late →

Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More!

Part I of my blog post set out the background and discussed the debate over Internal Revenue Code Section 965 “transition tax” or “mandatory repatriation tax” enacted in 2017. The Supreme Court recently decided to review the 9th Circuit case of Moore v. United States bringing this controversial tax back into the spotlight. The Court … Continue reading Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More! →

Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax

In recent years, one of the most hotly debated tax issues in the United States has been the imposition by Internal Revenue Code Section 965 of the “transition tax” or “mandatory repatriation tax”, a provision of the Tax Cuts and Jobs Act (TCJA) enacted in 2017. The Supreme Court's recent decision to review the 9th … Continue reading Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax →

Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties

As predicted, the fallout from the United States Supreme Court decision in Bittner v. United States, means a tougher stance by the Internal Revenue Service (IRS) when it comes to reducing so-called “FBAR” penalties for “nonwillful” violations. In a nutshell, the Bittner court held that the Bank Secrecy Act (BSA) $10,000 maximum penalty for the … Continue reading Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties →

“Net Investment Income Tax” is Hitting More Taxpayers … Americans Abroad Really Feeling the Pinch

The 3.8% Medicare surcharge, more commonly called the “Net Investment Income Tax” or (“NIIT”), was enacted to help fund “Obamacare” health coverage. It is imposed on “high wage earners” but because the NIIT thresholds are not subject to inflation, the rules are now grabbing more and more taxpayers. President Biden’s Green Book proposals if enacted … Continue reading “Net Investment Income Tax” is Hitting More Taxpayers … Americans Abroad Really Feeling the Pinch →

US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter)

On Wednesday I presented a webinar for the Financial Planning Association’s July International & Cross-Border Planning Knowledge Circle. My webinar highlighted numerous US tax issues when safeguarding the finances of the elderly (or other vulnerable individuals), whether Stateside or overseas. You can listen to the entire webinar here. The Case of the Wicked Stepdaughter A … Continue reading US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter) →

Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)?

Unsurprisingly, many taxpayers are confused about the tax results of expatriation. One of the most common questions is whether, after having expatriated, but before receiving the CLN, the individual is liable for US tax on his worldwide income. This question likely stems from the Department of State (DOS) policy that while issuance of the CLN … Continue reading Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)? →