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 →

What Tax Advisers Should Tell U.S. Clients Moving to Latin America

I am proud to share this article published by Bloomberg Tax (April 30, 2025), co-authored with Sofia Larrea, a dynamic young attorney based in Ecuador. As Latin America strives to be more noticed on the world stage, here are some important pointers about its tax laws and community property regimes which impact US taxpayers who … Continue reading What Tax Advisers Should Tell U.S. Clients Moving to Latin America →

Does Pope Leo XIV Have to File an FBAR? U.S. Citizenship and God’s Bank

Yesterday, the world welcomed Pope Leo XIV, a U.S. citizen, as the newly elected Pope, marking a historic moment for the Catholic Church. But amid the papal fanfare, a quirky tax question arises: could His Holiness need to file a Report of Foreign Bank and Financial Accounts (FBAR) for the Vatican Bank’s accounts? It’s a … Continue reading Does Pope Leo XIV Have to File an FBAR? U.S. Citizenship and God’s Bank →

Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely

The Additional Child Tax Credit can provide taxpayers up to $1,700 per qualifying child in 2025 as a refundable credit. The ACTC not only reduces the amount of tax owed but can also result in a refund from the IRS if the credit exceeds the tax liability. Non-refundable credits can only reduce a taxpayer’s tax … Continue reading Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely →

The Hendler Case: FBAR Penalties Survive Beyond Death

A recent decision reminds taxpayers and the tax compliance community of the importance of filing the Report of Foreign Bank and Financial Accounts. The U.S. District Court for the Southern District of New York in United States v. Hendler, 23 Civ. 3280 (Sept. 17, 2024) has clarified the enduring nature of penalties tied to FBAR. … Continue reading The Hendler Case: FBAR Penalties Survive Beyond Death →

Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules

When it comes to estate planning, how you hold property with others can have significant tax implications after you have passed on. Internal Revenue Code Section 2040 governs how joint ownership of property with right of survivorship is treated for federal estate tax purposes. The rules can catch even the most astute investors off guard. … Continue reading Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules →

Foreign Stock Options: 6 Things American Expats Should Know

As more Americans take on international roles, stock options have become a key part of the expatriate executive’s compensation package, especially when working for foreign employers. These options offer exciting opportunities to benefit from a company’s growth, but they also come with complex U.S. tax implications that can catch the unwary off guard. Imagine you’re … Continue reading Foreign Stock Options: 6 Things American Expats Should Know →