Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024

Revenue Procedure 2023-34 was released by the IRS on November 9, 2023. It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024 →

Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)?

Unsurprisingly, many taxpayers are confused about the tax results of expatriation. One of the most common questions is whether, after having expatriated, but before receiving the CLN, the individual is liable for US tax on his worldwide income. This question likely stems from the Department of State (DOS) policy that while issuance of the CLN … Continue reading Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)? →

US Recipients of Gifts or Inheritance from a Former American: The Importance of Record-Keeping to Avoid Transfer Tax Liability

Did someone you know and love give up their US citizenship or a green card held for a significant time? If so, that former US individual may at some point in the future, give you a gift or leave you an inheritance. If you are a US person here’s what you need to know to … Continue reading US Recipients of Gifts or Inheritance from a Former American: The Importance of Record-Keeping to Avoid Transfer Tax Liability →

IRS Updates its Audit “Campaign” Targets – Who’s on the List?

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? →

Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?

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? →

Free for You: My Cross-Border Tax Presentation for the Financial Planning Association

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 →

Breaking! Gird Your Loins for Greater FBAR Penalties! Supreme Court Denies Review in Toth/ Excessive Fines Issue

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 →

Treaty Tie-Breaker: Oh the Pitfalls Beware!

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! →

US Tax Inflation Adjustments for 2023 – Impact on the International Family

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 →

US Citizenship: Do You Really Want It? Brave New World – Assisted Reproductive Technology / Surrogacy / Same-sex Marriage

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 →