Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
For the past 6 years, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division shifted to a new audit strategy known as “campaigns.” This shift in focus concentrates on examining tax issues that will have the broadest impact on tax compliance while making the most efficient use of IRS’s resources. Given funding issues … Continue reading IRS Updates its Audit “Campaign” Targets – Who’s on the List?
The title of this post could also be “What a Difference a Day Makes”. Most of my readers are quite familiar with the expatriation regime, as I have written many blog posts on this topic. Before delving into the question of the date to use when working through Form 8854, let’s have a quick review … Continue reading Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?
On March 15, I was delighted to present cross-border tax topics of interest for the Financial Planning Association (FPA). FPA is a well-known membership organization for certified financial planner professionals and those engaged in the financial planning process. It provides its members with practice support, learning, advocacy, and networking. As a tax professional, with 40 … Continue reading Free for You: My Cross-Border Tax Presentation for the Financial Planning Association
United States v. Toth: Just yesterday, the United States Supreme Court denied review of Toth, a case being carefully followed by tax professionals who deal with FBAR cases, US persons abroad, and all things "foreign". Toth was an FBAR “willful” penalty case on appeal to the First Circuit, with one of the issues being whether … Continue reading Breaking! Gird Your Loins for Greater FBAR Penalties! Supreme Court Denies Review in Toth/ Excessive Fines Issue
The United States is unique in its approach to taxing individuals who are US citizens or lawful permanent residents (green card holders). Such individuals are taxed on worldwide income regardless of where they may reside. On account of this taxation approach, US citizens and green card holders who live outside of America may be subject … Continue reading Treaty Tie-Breaker: Oh the Pitfalls Beware!
Certain provisions in the United States Internal Revenue Code (Code) are tied to inflation to prevent rising prices from resulting in higher taxes. Annual inflation adjustments have been part of the tax rules for well over 2 decades. These formulas set by Congress help prevent inflation from nudging taxpayers into higher tax brackets and increasing … Continue reading US Tax Inflation Adjustments for 2023 – Impact on the International Family
My earlier blog post discussed some of the complications that arise when certain individuals wish to renounce their US citizenship. The would-be renunciant must give up US citizenship “voluntarily” and with the requisite “intention” in order to meet the legal requirements for an effective renunciation. This can be a difficult hurdle to surmount in the … Continue reading US Citizenship: Do You Really Want It? Brave New World – Assisted Reproductive Technology / Surrogacy / Same-sex Marriage
I am now frequently receiving more and more expatriation inquiries from the foreign parents of a child born in the United States while the parents were studying there or were otherwise in America on some other temporary basis. “Jus soli” (the law of the soil) is a rule of common law followed by the US, under … Continue reading Special Hurdles: Expatriation of Minors / Mentally Challenged Individuals
Join the webinar on August 23 Tuesday at 12 noon EDT. Register here Tax pro's: A new line of business awaits if you are prepared to explain the expatriation process, assist with the various Department of State forms, provide guidance to handle the State Department interview, to approach the written statement of reasons for expatriation … Continue reading LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP
Part I of this blog post examined the US tax issues faced by the Duke of Sussex who moved with Duchess Meghan to Los Angeles in March 2020. Given the significant number of days of physical presence in America, Prince Harry has most likely already met the "substantial presence test" and is being taxed the … Continue reading Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?
Virginia - US TAX TALK 