Category: Americans Overseas

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 →

FBAR – It Gets You in the End, Presidential Pardon Notwithstanding

Can a presidential pardon forgive FBAR penalties?  Maybe Paul Manafort Jr. thinks so! Despite notice and demand for payment, he is not paying US$2.9 million in “willful” FBAR penalties assessed against him.  The US government just brought an action in the southern district court (West Palm Beach division 4/28/2022), to collect the outstanding civil penalties … Continue reading FBAR – It Gets You in the End, Presidential Pardon Notwithstanding →

Expatriation and Tax Compliance – IRS Fails to Process the Tax Return

As a tax practitioner I have assisted many taxpayers for decades with expatriation issues (i.e., relinquishing US citizenship or a green card held for at least 8 tax years).  In the best case scenario, the taxpayer can avoid being treated as a "covered expatriate" (CE). Sometimes tax planning, correcting tax returns or submitting delinquent international … Continue reading Expatriation and Tax Compliance – IRS Fails to Process the Tax Return →

Recent FBAR Case: IRS Seeks “Willful” Penalty $8.8M Without Much Regard for the Facts

A very recent FBAR case teaches us a few things.  My colleague, attorney John Richardson, noted this after reading the case: "When charities need to raise money they will often have a bake sale or an auction. When the US government wants to raise money it uses an 'FBAR Fundraiser'". Readers, draw your own opinion! … Continue reading Recent FBAR Case: IRS Seeks “Willful” Penalty $8.8M Without Much Regard for the Facts →

Oops… Made a Mistake on an FBAR?

The Bank Secrecy Act (BSA) contained in Title 31 of the United States Code, requires that every year US persons must report certain foreign financial accounts, such as bank accounts, brokerage accounts and mutual funds, to the Treasury Department and to keep certain records with regard to these accounts.  The reporting is done by filing … Continue reading Oops… Made a Mistake on an FBAR? →

Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

Today's post, Part II, was written with my colleague John Richardson, J.D. Part I of this blog post discussed President Biden's Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death.  To recap, the major thrust of the Green Book proposal is to treat gifts … Continue reading Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard →

“With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)

Today's post is in two parts and was written with my colleague John Richardson, J.D. On March 28, President Joe Biden released the FY2023 Budget, also known as the Green Book, available here.   The Green Book is not proposed legislation, but it might be viewed as a kind of reading of the tea leaves showing … Continue reading “With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I) →

Treasury Inspector General Says FATCA is a Big Fat Flop ….So Far

The Treasury Inspector General for Tax Administration (TIGTA) just issued a damning report on FATCA:  Additional Actions Are Needed to Address Non-Filing and Non-Reporting Compliance Under the Foreign Account Tax Compliance Act (Report # 2022-30-019 4/7/22), available here. The TIGTA audit was undertaken to evaluate IRS efforts to actually use the reams and reams of … Continue reading Treasury Inspector General Says FATCA is a Big Fat Flop ….So Far →