Americans Abroad: Sept 18, LONDON – Push to End Citizenship-Based Taxation

A lively discussion is set to drum up support to convince US lawmakers to end America’s increasingly-unpopular “citizenship-based” tax regime. The meeting will take place in London next week. When: Tuesday 18 September 2018 - 17:30 to 19:00 Where: Central London location – to be confirmed upon RSVP (nearest tube: Westminster) Venue: To be provided upon RSVP (nearest … Continue reading Americans Abroad: Sept 18, LONDON – Push to End Citizenship-Based Taxation →

MORE Real Life Examples: US Tax Traps of International Community Property

Part I of my blog post explained the basics of community property and how US tax laws can override certain community property principles when a US/NRA married couple is involved. This was followed by a blog post posing a smattering of real-life examples that demonstrated how community property laws can impact the US tax situation … Continue reading MORE Real Life Examples: US Tax Traps of International Community Property →

New FBAR “Willful” Penalty Case: But You Can’t Blame the IRS!

I don’t have much to say about this case, simply because not much needs to be said. In United States v. Gentges (USDC SDNY Dkt. 7:18-cv-07910), the Government is bringing a lawsuit to collect a “willful” FBAR penalty for the tax year 2007 in an amount close to USD904,000. The penalties relate to two Swiss bank accounts … Continue reading New FBAR “Willful” Penalty Case: But You Can’t Blame the IRS! →

OVDP Ending / IRS To Announce New Procedures

The Internal Revenue Service (IRS) reminded taxpayers yesterday that they have until September 28 to apply for the Offshore Voluntary Disclosure Program (OVDP). In March, the IRS announced the program would end on the 28th of this month. The IRS has made clear that it will continue to hold taxpayers with undisclosed offshore holdings accountable after … Continue reading OVDP Ending / IRS To Announce New Procedures →

Katholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty

I have been blogging recently (here and here) about the IRS’ aggressive stance in determining what constitutes a taxpayer’s “willful” failure to file an FBAR and the fact that mounting court cases show the judiciary is buying in to the IRS’ position. Courts appear to be more easily upholding a finding of “willfulness” when it … Continue reading Katholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty →

Real Life Examples: A US Tax Mess, International Community Property

Attention all mixed nationality couples, with one spouse having US citizenship or US resident status while the other is a nonresident alien (NRA)! Your tax advisor should be looking at all possible issues surrounding your fact pattern. If you live in a foreign jurisdiction or US state (there are 9 of them) with a community … Continue reading Real Life Examples: A US Tax Mess, International Community Property →

Tax Primer: US Expats & Foreigners

Everything you need to know about US tax is right here at your fingertips! My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners →

Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles

Do I have to pay tax on that? Get the full scoop in today's post! “Expat” taxpayers living abroad are often given certain perks from their employers that would not be provided if the individual remained State-side. For example, provision by the employer for airline tickets home for the taxpayer and his/her family; or payment … Continue reading Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles →

IRS Rehires Over 200 Previously Fired Employees – Makes a Mockery of Taxpayer Justice

Shame on the IRS! So abhorrent is the agency’s conduct in re-hiring employees who were fired for serious misconduct (think unauthorized access to taxpayer accounts, falsifying official documents, felony possession of a forgery device, lying about previous criminal convictions on employment forms, past tax problems including -“willful” tax noncompliance)- that Congress may have to step … Continue reading IRS Rehires Over 200 Previously Fired Employees – Makes a Mockery of Taxpayer Justice →

The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations. Two courts have limited the FBAR “willfulness” penalty to $100,000 because the Department of Treasury did not update the relevant regulations to match the statute as revised by Congress in 2004. Essentially the dispute … Continue reading The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance →