On September 19, 2025, the U.S. District Court for the Northern District of Texas upended IRS FBAR enforcement in United States v. Sagoo (No. 4:24-cv-01159, N.D. Tex. 2025). Sharnjeet Sagoo, a U.S. taxpayer with international ties, faced over $1 million in penalties for alleged willful failures of the Bank Secrecy Act requirement to report foreign … Continue reading The Sagoo Case: FBAR’s Reckoning In A Globalized World
Category: Americans Overseas
What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025
Thinking of moving overseas, or already living abroad as an American? One thing you can’t escape is U.S. taxes. In this video, I sit down with Jahtna Hernandez to discuss the unique challenges Americans face under a citizenship-based tax system, and the key rules every expat, retiree, or digital nomad needs to know in 2025. … Continue reading What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025
A Tale Of Two Retirees: New Senior Tax Deduction And Foreigners’ Social Security
While a campaign promise by President Donald Trump to eliminate income taxes on Social Security benefit income was not fulfilled, seniors were granted certain relief. The landmark tax legislation, the One Big Beautiful Bill Act (H.R. 1), signed into law on July 4, 2025 introduced a temporary special deduction for taxpayers aged 65 or older. The Social Security Administration … Continue reading A Tale Of Two Retirees: New Senior Tax Deduction And Foreigners’ Social Security
The Danger Of Relying On AI For U.S. Tax Advice
Artificial intelligence tools such as ChatGPT and Grok are becoming household fixtures with Americans increasingly turning to them. These tools are being used to find answers on everything from cooking recipes to complicated tax questions. How reliable is AI for taxpayers seeking tax advice, particularly on U.S. international tax issues? While AI has laudable capabilities … Continue reading The Danger Of Relying On AI For U.S. Tax Advice
WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know
Some exciting news. I am presenting a webinar on Monday, July 28 2025. 2 IRS CPE credits. 12:00 PM ET | 11:00 AM CT | 09:00 AM PT 90 MINUTES Hope to see you there. Please share with your colleagues and friends who may have interest in this topic. REGISTER AT THE LINK: https://educatorprime.com/product/remote-work-global-teams-u-s-tax-what-every-cpa-and-ea-needs-to-know WEBINAR … Continue reading WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know
Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax
In the heart of America’s immigration debate, a lesser-known but seismic issue is emerging. The intersection of denaturalization and the expatriation tax regime is an explosive topic that has not yet been explored. If the expatriation regime applies to a denaturalized citizen, it imposes an exit tax through a deemed sale of worldwide assets as … Continue reading Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax
New Self-Employment Tax Risks For U.S. Investors In Global Funds
The U.S. Tax Court decided Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) in May 2025 leaving financial, tax and legal advisors concerned. The court upended assumptions about the self-employment tax exemption for limited partners in hedge funds, and by analogy to venture capital, and private equity partnerships both in the U.S. and abroad. U.S. … Continue reading New Self-Employment Tax Risks For U.S. Investors In Global Funds
Why Pope Leo Can Skip FATCA, But Not FBAR
There has been a lot of discussion about the possible U.S. tax obligations for Pope Leo XIV, the first U.S. citizen Pope. Some of the assertions have generated confusion, leaving key U.S. tax concepts insufficiently addressed. One of the biggest areas of misunderstanding has been the Pope’s possible FBAR reporting (FinCEN Form 114) versus FATCA … Continue reading Why Pope Leo Can Skip FATCA, But Not FBAR
WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR!
Learn all about FBAR and expand services to your clients with confidence. Maybe even land Pope Leo XIV as a new client since his Holiness probably has to file FinCEN Form 114 for the Vatican Bank's accounts. Understand your own compliance risks and what to do if you are not compliant. This is the FBAR … Continue reading WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR!
One Big Beautiful Revenge Tax: Hits Foreigners From “Unfair Tax” Jurisdictions
The U.S. House of Representatives just passed H.R. 1, the “One Big Beautiful Bill Act” by a narrow margin, with the vote being 215 to 214. Foreign persons (including foreign governments) considering inbound investments should pay close watch as this develops. The OBBBA has many tax provisions, but one (Section 112029 of the OBBBA) would … Continue reading One Big Beautiful Revenge Tax: Hits Foreigners From “Unfair Tax” Jurisdictions








