Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates

Proud to announce publication of my article Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates in Tax Notes International (TNI) Vol. 98 No. 5 May 4, 2020. Available at no cost on SSRN. The article discusses the US tax treatment of the newest "foundations" … Continue reading Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates →

Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now

The US gift tax is a tax imposed on the transfer of property by way of gift. The giver of the gift (the donor) is the party who must pay the tax. Generally, any transfer to an individual without receiving something of equal value in return (measured in money or money's worth) is treated as … Continue reading Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now →

Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test

Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE). In addition they may be able to exclude certain amounts paid for foreign housing using the Foreign Housing Exclusion (FHE). Both of these benefits are … Continue reading Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test →

Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

On April 9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments →

No FEIE/ Section 911 Exclusion – Taxpayers With a US “Abode”

With tax filing time looming, US taxpayers abroad should take heed when claiming the Section 911 “Foreign Earned Income” and “Foreign Housing Exclusion” benefits (FEIE). Two recent cases show how easy it is to lose the FEIE benefits granted to qualifying taxpayers living and working in a foreign country. (My blog post here explains the … Continue reading No FEIE/ Section 911 Exclusion – Taxpayers With a US “Abode” →

Extension Granted for Gift Tax Returns and Payments – No Extension for Form 3520

My earlier blog post detailed the extensions for filing and payment of US income taxes on account of the COVID-19 emergency. Further relief was just granted on March 27 by the Internal Revenue Service (IRS) in Notice 2020-20 to all taxpayers who have Federal gift (and generation-skipping transfer) tax returns and payments due on April … Continue reading Extension Granted for Gift Tax Returns and Payments – No Extension for Form 3520 →

Eating Out Again – Yes, the Day Will Come Back… Business Deductions for Entertainment and Meals

In the midst of the COVID-19 pandemic, most everyone is staying home; entertainment and meals outside the home bubble are not on the agenda. But, someday, life will return to normal and we will eat out again! The economy will pick up and clients, prospective customers and associates will look to meet and enjoy a … Continue reading Eating Out Again – Yes, the Day Will Come Back… Business Deductions for Entertainment and Meals →

Tweets Rule…. Tax Filing Extended from April 15 to July 15 / What About FBAR?

While I was peacefully asleep in Dubai (we do have an 8 hour time difference to the East Coast of the USA), Secretary of the Treasury Steven Mnuchin announced in a tweet that “Tax Day” is being moved from April 15 to July 15. For those who fear that Tweets may not be a reliable … Continue reading Tweets Rule…. Tax Filing Extended from April 15 to July 15 / What About FBAR? →

Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household”

Tax filing time is upon us! Selecting the best tax filing status is an important element of tax planning and should not be taken lightly. For US persons who are married to foreigners (so-called "nonresident alien individuals", or "NRA"), special considerations come into play. Making the decision how to treat your foreign spouse for US … Continue reading Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household” →

Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light?

The Internal Revenue Service (IRS) - starting to see some light with respect to "foreign" pension plans? The US tax issues surrounding foreign pensions and retirement schemes is extremely complex and has vexed tax professionals and US persons abroad for many years. (Read my earlier blog post here). Due to the diversity of such plans, … Continue reading Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light? →