Category: Americans Overseas

Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?

There are good lessons in today's post for any individual who is considering attaining "US status" - be it by obtaining a green card, US citizenship or through extended physical presence in America. The lessons are explained in detail in a 2-part blog post and will be helpful to Prince Harry who may possibly take … Continue reading Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family? →

Is the IRS Being Reasonable when it comes to “Reasonable Cause”?

My recent blog post discussed how I approach “streamlined procedure” filings for taxpayers with unreported income, for example, from offshore assets or accounts. Often, the tax noncompliance for such cases involves unfiled international information returns as well.  As discussed in the blog post, I draft the required statement of non-willfulness in such a manner that … Continue reading Is the IRS Being Reasonable when it comes to “Reasonable Cause”? →

IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates

The Treasury Inspector General for Tax Administration (TIGTA) has been documenting some careless work being carried out by the Internal Revenue Service (IRS).  We have the most recent TIGTA report (Number 2022-40-036) of May 4, 2022 reporting that the IRS destroyed 30 million “paper-filed information return documents” without bothering to process them beforehand. This destruction … Continue reading IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates →

FBAR Penalty & the US Supreme Court: If the Penalty is “Per Form”, are “Per Account” Penalty Refunds Possible?

My earlier blog posts discussed the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” rather than “per form” basis. The Fifth and Ninth circuit courts disagree on the statutory interpretation of the Bank Secrecy Act (BSA) (31 U.S.C. § 5321(a)(5)(B)(i)), particularly what constitutes … Continue reading FBAR Penalty & the US Supreme Court: If the Penalty is “Per Form”, are “Per Account” Penalty Refunds Possible? →

Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays

The Internal Revenue Service (IRS) Streamlined Procedures of 2014 are still available for taxpayers with tax noncompliance issues that involve unreported income from a foreign financial asset. The Procedures can help taxpayers who have not filed certain information returns associated with the foreign asset (e.g., Form 8938; Form 5471 pertaining to ownership in a foreign … Continue reading Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays →

US Supreme Court to Decide: FBAR Penalty, $10K per Form or per Account?  

The US Supreme Court just agreed to resolve the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” rather than “per form” basis.  By granting certiorari to Mr. Bittner, a taxpayer who petitioned the Court to review his case, we will finally have a … Continue reading US Supreme Court to Decide: FBAR Penalty, $10K per Form or per Account?   →

Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception

The economy is not looking good with the stock market dropping sharply, with tech companies being hit most dramatically, dropping by about 40%.  Crypto markets are also in a freefall and liquidity has dried up. As a result, it may be the perfect time for individuals wishing to relinquish green cards held for a long … Continue reading Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception →

Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship

Curious about what it means from a US tax perspective if you give up your green card or US citizenship?  You really should know BEFORE you take the plunge and apply for that green card or obtain US citizenship. Tax pro's -- Want to expand your client reach by advising and planning with confidence about “expatriation”? … Continue reading Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship →

US Residency “First Year Election” and FBAR – The Devil is in the Details

Recently, I presented a webinar for tax pro’s earning CPE credits; the topic involved our favorite character, Mr. FBAR. The FBAR, Form 114, is more formally known as the Report of Foreign Bank and Financial Accounts.  The webinar will be available soon as a CPE credit "self-study" program.  Send me an email if you wish … Continue reading US Residency “First Year Election” and FBAR – The Devil is in the Details →