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 →

PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More

A very informative podcast - I would say it's a crash course on the US #expatriation regime including the recently issued final IRS regs on the Sec. 2801 transfer tax, lots of tax tips including gifting issues to get below USD 2 million threshold, what NOT TO DO if CBP wants you to sign I-407 … Continue reading PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More →

FBAR Due Date: Triggers And Key Compliance Rules For U.S. Taxpayers

As the April 15 tax filing deadline approaches, U.S. persons with foreign financial accounts must be aware of their obligation to file the Report of Foreign Bank and Financial Accounts, commonly called the “FBAR”. The filing deadline is April 15, the same due date as one’s U.S. income tax return, but there is an automatic … Continue reading FBAR Due Date: Triggers And Key Compliance Rules For U.S. Taxpayers →

Unfiled Tax Returns Can Lead To An IRS Action That Costs You Money

With tax filing season in full swing, it’s important to understand what might happen if you do not file a U.S. income tax return. The IRS can, and often will, file a “substitute” return for you and generally, it won’t be favorable. Taxpayers living and working abroad face greater risks with a SFR. The IRS … Continue reading Unfiled Tax Returns Can Lead To An IRS Action That Costs You Money →