Own A Foreign Corporation? New Case Lets IRS Collect $10K Immediately

A new court case now allows the IRS to immediately collect $10,000 penalties from U.S. owners of foreign corporations who fail to file Form 5471. For taxpayers with foreign corporations, the IRS just strengthened its hand in collecting reporting penalties without going to court. The so-called “Farhy defense” suffered another major blow on February 27, … Continue reading Own A Foreign Corporation? New Case Lets IRS Collect $10K Immediately →

BREAKING! Ex-U.S. Crypto Mogul Indicted: The High Cost of Botched Expatriation

In a stark reminder of the complexities and pitfalls of renouncing U.S. citizenship, a federal grand jury in the Western District of Texas recently indicted Justin Ryan Schmidt on multiple tax-related charges. Mr. Schmidt, a Cayman Islands national, is a former U.S. citizen and cryptocurrency hedge fund manager. He became a naturalized British citizen in … Continue reading BREAKING! Ex-U.S. Crypto Mogul Indicted: The High Cost of Botched Expatriation →

IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?

Right before the U.S. tax filing season officially opened on January 26, the Internal Revenue Service announced significant leadership changes that have drawn cautious scrutiny from tax professionals. Practitioners with the high-net-worth clients and those who assist Americans living abroad are paying close attention. While IRS leadership transitions regularly occur, the timing and substance of … Continue reading IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming? →

Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF

The United States along with over 70 other countries has adhered to the Joint Statement on the OECD’s Crypto-Asset Reporting Framework, “CARF”. CARF is the digital-asset counterpart to the Common Reporting Standard “CRS” that has exchanged bank and securities account data among signatory countries (now well over 100 countries). The United States has formally indicated … Continue reading Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF →

Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory

In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory →

Unregistered U.S. Citizenship: Hidden Risks For American Born Abroad

Each year, thousands of children are born overseas to one U.S. citizen parent and one non-U.S. parent. Under U.S. immigration law, many of these children are U.S. citizens from birth, provided the American parent satisfies a relatively simple test: at least five years of physical presence in the United States, with two of those years … Continue reading Unregistered U.S. Citizenship: Hidden Risks For American Born Abroad →

Forms W-8BEN and W-9: Which to Use, When, and Why Many Get It Wrong

It is crucial to understand the differences between Form W-8BEN and Form W-9 when receiving payments from U.S. sources. This is especially so if the taxpayer operates, invests, or maintains financial accounts overseas. Many taxpayers get this wrong, often to their detriment. This article provides the guidance needed to understand which form is required and … Continue reading Forms W-8BEN and W-9: Which to Use, When, and Why Many Get It Wrong →

A Complicated U.S. Tax Life: Foreign Spouses And Community Property

When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property →

Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!

Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews! →

Residence-Based Taxation: Social Security, Pensions And 30% Withholding

The endorsement of an elective residence-based taxation model by former IRS Commissioner Charles Rettig and former IRS Commissioner Counselor Tom Cullinan, covered in my earlier Forbes article, has sparked important discussions about fairness for Americans abroad. Their piece highlights the burdens of America’s citizenship-based tax system and calls for a shift to treat expats more … Continue reading Residence-Based Taxation: Social Security, Pensions And 30% Withholding →